Subject: S7-18-21: WebForm Comments from Brian Leysath
From: Brian Leysath
Affiliation:

Oct. 09, 2022



October 9, 2022

 October 9th, 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.

I feel that any rule that increases transparency in the financial markets can only help it will help companies more quickly identify when short positions are being taken against them, it will help bring light to potential naked short selling which, while illegal, appears to be occurring against particular stock symbols with alarming frequency.  Having more information available can only help the retail investor, those you are paid to protect.

The idea that reporting this information would be cost prohibitive in this age of computers, algorithms, and high frequency trading is laughable - these hedge funds spend billions on their trading systems, making thousands upon thousands of trades a day. Surely these systems are capable of handling the compiling and reporting of this data every 15 mins.

For far too long, the professional market makers and hedge funds (sometimes the same companies, which I dont understand how that is legal) have had the upper hand though PFOF, hiding of price discovery via dark pools, and front running trades.  The time to level the playing field is long overdue - but approving S7-18-21 is a step in the right direction.



Sincerely,

A Concerned Investor