Oct. 10, 2022
October 10, 2022 October 10th, 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. Too many institutional investors have become predators preying on their victims in the dark. As you (the SEC) have so wisely pointed out regarding (quote) the insufficient data that is actually available, Only subscribers can use those systems to receive information regarding securities lending transactions. Moreover, as the private systems capture data only from their subscribers, the available data is not complete, nor is the transaction data captured by these private vendors available to the general public without a subscription, or available in one centralized location - (SEC Overview, Executive Summary). As a typical retail investor, I do not have the resources to be a subscriber, nor to make being a subscriber to these databases profitable. Furthermore, I (as with most retail investors) do not have the time to analyze it in order to profit from the data. It is true, institutional investors may profit less from having to be so transparent, but they often use the lack of transparency in illegal ways - which they are occasionally fined for, but the fines are so impotent that the offenders still profit immensely. Therefore, the net effect is that they are incentivized to commit crimes. Furthermore, they fail to explain (in their comment on this proposal) that in many cases, their profits come from their illegal activities that so often rob from honest retail investors. In effect, they act like mob bosses benefitting their minions at the expense of the innocents. I wholeheartedly agree with your efforts to bring greater transparency to lending practices in order, to oversee transactions that are vital to fair, orderly, and efficient markets. Otherwise, it is simply a rigged system to benefit criminal enterprises. Your observation (objective) that, (quote)increasing the accessibility of data could lower barriers to entry for would-be participants in the securities lending market as well as the securities markets more broadly because all market participants, not just counterparties to a trade or those that subscribe to certain services, would be able to view and analyze transactions that are taking place in the securities lending market - (SEC Overview), will go a long way in reforming this apparent criminal enterprise into a true market for all investors (and would be investors). Your proposal must not be watered down. They must report on every transaction (aggregate reporting simply removes the transparency this initiative is seeking. They must also report them within 15 minutes, and failure to comply with these requirements must be met with penalties stiff enough to deter them (i.e. greater than the amount they profit from) from trying to get away with violating these requirements. Sincerely, Peter VanVleck A Concerned Investor