Subject: S7-18-21: WebForm Comments from Adam Whitehurst
From: Adam Whitehurst
Affiliation:

Oct. 08, 2022



October 8, 2022

 October 8th, 2022

Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609

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


Dear Secretary Countryman:

I am writing in strong support of rule 10c-1, Reporting of Securities Loans.

The regulations around short selling are problematic to say the least. They are opaque and easily exploited by privileged parties to destroy price discovery. This rule is a step in the right direction to ameliorate this problem as it will add transparency to the actions of those who would exploit the rules for their own gain.

This particular rule would hopefully shine light on where shares are borrowed from and that is a good thing. Currently, the origin and terms of borrowed securities are hidden and the SEC itself has noted that shares have been rehypothecated up to 30 () times. The more transparency that we have into audit trail of shares, the better. That is why I support this rule and believe even more rules around short sale reporting and restriction should be added.


Sincerely,

A Concerned Investor