March 11, 2022
To whom it may concern,
Real reform for securities lending must include:
(1) Notifying public about who is borrowing lending shares (not just which companys shares are borrowed or lent),
(2) 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),
(3) Sharing any revenue earned from lending their shares with retail investors,
(4) Eliminate Onward Lending completely (public companies transfer agents have opposed this for decades),
(5) Require every loan to have a due date (not if applicable).
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.