Oct. 08, 2022
October 8, 2022 Dear Secretary Countryman, I appreciate this opportunity to comment on proposed Rule 10c-1, Securities Lending Transparency, to implement intraday transaction-by-transaction reporting of all securities lending activity every 15 minutes, which I strongly support. Lack of transparency with respect to the short sale of securities by institutional market participants is a significant problem in the US securities market. A market that permits short selling to occur 'in the dark' and allows delayed reporting of short positions disproportionately subjects individual investors to risk, facilitates coordinated efforts by toxic market participants to devalue publicly traded American corporations, and prevents fair price discovery. Transaction-by-transaction reporting in near real-time enables regulatory agencies, third parties, and individual investors to identify predatory, abusive, and manipulative practices by toxic market participants and to react nimbly. Delayed aggregated reporting clearly fails to achieve this outcome, as the very nature of aggregation obscures data transparency on a granular level. Increasing the accuracy of reported data on short sold securities will reduce volatility, particularly volatility that is unrelated to the fundamentals of the American businesses underlying the securities. Increasing access to this data will 'level the playing field', reducing the inherent advantage institutional market participants have over individual investors due to their greater resources and sophisticated analysis methods. Finally, more stringent reporting requirements stabilize markets by reducing the ability for toxic market participants to conceal short positions in complex untracked securities lend ing chains. Sincerely, A Concerned Investor