Subject: File No. 4-590
From: Josh Galper
Affiliation: Managing Principal, Finadium LLC

September 30, 2009

Thank you for making public the SEC roundtable on securities lending and short selling. As an attendee, I had some comments on what I heard and wanted to clarify a few points on market transparency.

My firm, Finadium, is a consultancy in financial markets. A large portion of our work is in securities lending, collateral management, prime brokerage and custody. We produce a research report series and conduct assignments at many levels of the market in the US and Europe.

My comments are on how beneficial asset holders (the lenders of securities) manage their programs and benchmark their fees and returns.

Firstly, in our market surveys we have seen that while most beneficial asset holders appreciate that securities lending is an investment activity, not all of them have the resources to actively monitor their programs. Few if any asset holders now think that lending is an operational activity.

Secondly, it was mentioned that pension plans, mutual funds and other lenders lack tools for benchmarking their service provider fees. In fact, Finadium offers a benchmarking product for lenders of securities. Securities lending fees are not one-size-fits-all, but rather depend on a range of factors including risk profiles, types of asset lent, cash collateral management programs and other services provided. Our analysis takes these factors into account and provides feedback to the client by their peer group. Our findings have been used at the board level for determining appropriate fee levels.

Lastly, I would like the Commission to be aware that Standard and Poors has recently launched a series of securities lending indices. These indices are available to the public and offer a low cost means of benchmarking securities lending activity. The indices are available on Bloomberg and other market data outlets.

We deeply appreciate the involvement the SEC has taken on securities lending, and believe that a greater regulatory understanding of this subject will benefit many aspects of the US financial markets.