Subject: S7-08-22: WebForm Comments from ODogg
From: A Concerned Investor
Affiliation:

Oct. 10, 2022



October 10, 2022

 Dear Secretary Countryman,

I am writing in support of rule 10c-1, Reporting of Securities Loans.

Rule 10c-1, Securities Lending Transparency proposed transaction-by-transaction reporting of all securities lending activity. Transparency like this in the stock market is absolutely essential for all valued investors and reinstate confidence in the markets, which quite frankly has been massively damaged in the last 2-3 years. Given the SEC's goal of creating free and fair markets for all, there should not be any advantages given to broker-dealers, market makers and hedge funds - especially not in this magnitude.

To deny such transparency by rejecting rule 10c-1, would suggest to investors, a hidden agenda or ill-intention to keep truth hidden, of which would then present the question as to why.

Not only should short sales be reported to the same extent as long trades, but more attention should be paid to short trades which are marked 'long', which when investigated tend to attract puny fines which amount to a small percentage of the gain made by the offending party. Not only this, but short sale transparency would remove the need for market participants to use complex options strategies and swaps to hide short positions and delay/remove their obligations to deliver.

I am writing to you in strong support of rule 10c-1, Reporting of Securities Loans in the hope that the SEC will do all that they can to ensure that investors within these US markets remain fully informed, assured and confident with their investments as held within the NYSE.

I can only imagine the backlash the SEC would face if, in light of the information presented as above, they were seen to reject a rule like 10c-1, Reporting of Securities Loans and how this might lead to a loss of confidence and trust in the American Markets causing people to withdraw their funds on mass (not only US-based stockholders, but international investors too). Not only would that impact the integrity of the NYSE but I should imagine it would have devastating affects on the dollar. Being that Im sure you are every part as invested, being the SEC, in protecting these American markets (being that you are funded by the US tax payer to do so) Im sure you will agree with me the necessity in implementing rule 10c-1, Reporting of Securities Loans.

After all, I see no good argument against more transparency and integrity within our financial markets, nor any good reason to oppose rule 10c-1, Reporting of Securities Loans. Should this rule be wrongfully rejected, the SEC needs to make a statement as to why, and how that decision benefits all market participants, including retail investors.

Sincerely,

A Concerned Investor