Feb. 18, 2022
My comment is as follows: With regard to securities lending, I am of the same opinion as Dr. Susanne Trimbath who says, “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”). 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 broker’s cost/benefit analysis in favor of fails.” Any rule changes that only partially resolve the above issues, that do not prioritize timely resolution, or that simultaneously create new loopholes for bad actors to exploit—and most everyone whose income exceeds a certain level is a sociopath—are less than half measures. It’s equivalent to trying to stop a ship from sinking by plugging holes in the hull with chewing gum: an ineffectual, disgusting waste of time that would be comical if it weren’t so damn sad. Fix the broken market, you clowns… or don’t. Whatever you think’s best, governing officials who have the citizenry’s best interests at heart. Tim Windy