April 20, 2022
This rule is extremely concerning and should not be passed. The rule encourages the SEC to abandon their mandate to protect investors by enabling further obscuration and delay of closure for institutions and financial entities with substantial short positions including, but not limited to: short options, effective short swap positions, \"naked\" short positions through etf forming and redemption, and failure-to-delivers from these and more basic security trades. Those entities who stand to benefit from the rules changes proposed here would be able to continue to hide the magnitude of their unrealized losses while unwinding it so that the losses are socialized. Rather than forcing players to reveal and close their \"bad bets\", this rule promotes the distribution of losses. To be blunt this is the equivalent of someone ditching the check at the restaurant and the police arresting the other patrons for not grouping together to pay for a strangers huge bill. This is the opposite of the free market which the SEC is tasked with maintaining. This is price obscuration, not price discovery, and the rule simply should not be passed.