December 16, 2021
I am a retail investor who started getting into stock trading as I was stuck at home during the pandemic. I have witnessed unfair practices that continue to this day with little change by the SEC.
You should be notifying the public about who is borrowing lending shares (not just which companys shares are borrowed or lent), This can show if there is collaboration or gang mentality versus a company.
Notifying retail investors that their shares are being lent, (because (a) they don't get to vote (b) they don't get tax-qualified dividends), This is because when our shares are held at a broker they are held in the brokers name. Retail investors shares should be held in their own name not a brokers name.
Sharing any revenue earned from lending their shares with retail investors, They are literally OUR SHARES Why do brokers get to not only make money from lending our shares but can also be harmful to our own investments because the shares are being lent out TO SHORT COMPANIES, causing retail to loose on their investments.
Eliminate Onward Lending completely (public companies transfer agents have opposed this for decades), Enough Said about this point.
Finally, it seems likely that Proposed Rule will increase cost and reporting burden of borrowing stock for any reason (cover short sales, close fail-to-deliver, access voting rights, etc.). Unintended consequence may be to tilt brokers cost/benefit analysis in favor of fails.