Subject: S7-18-21 (SEC proposed Rule 10c-1)
From: Eric Marhefka
Affiliation:

Dec. 17, 2021


I am a retail investor and these are my recommended comments on S7-18-21 (SEC proposed Rule 10c-1). 


Real reform for securities lending must include:


(1) Notifying public about who is borrowing & lending shares (not just which company’s 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”). 


Now is the Time for Change


Thank You