Apr. 22, 2022
To whom it may concern, Real reform for securities lending must include: 1. Notifying the public about who is borrowing and 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, and (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 (something that public companies and transfer agents have opposed for decades); 5. Require every loan to have a due date (not 'if applicable'). It seems likely that the proposed rule will increase cost and reporting burden of borrowing stock for any reason (cover short sales, close fail-to-delivers, access voting rights, etc.). Unintended consequences may be to tilt the brokers' cost/benefit analysis in favor of fails. Thanks. Chris