Subject: S7-18-21: WebForm Comments from Julian Young
From: Julian Young
Affiliation: Asset Manager

Aug. 16, 2022

August 16, 2022

 Re: Reporting of Securities Loans (File No. S7-18-21)

Dear Ms Countryman

I appreciate the opportunity to provide comments to the Securities and Exchange Commission on the proposal to require securities lending transactions to be publicly reported within 15 minutes of being effected.

May I first say I am strongly in favour of the preposed rule S7-18-2.

Wether or not it is widely recognised or understood, it is my view that the entire financial system is currently at risk from long obscured, untracked, derivative,  lending chains. In fact, in my view it is the single biggest threat to our economy.  Securities lending should not done in the dark and without oversight, and this rule goes some of the way to fixing these obvious shortcomings.

I thoroughly support Transaction-by-transaction reporting as it allows sunlight into trading, and may allow the SEC to better see the risk(s) the market faces and overcome them.

Companies in America have been routinely victimised and destroyed as a result of nefarious short selling strategies and having a grater accountability would go some way in preventing this. This rule would also allow these victimised companies to have redress.

I am extremely happy to see the SEC finally standing up to members of our industry, members who for far to long gamed the system and put the entire US economy at risk.

Yours sincerely

Julian Young