Oct. 11, 2022
October 11, 2022 I am writing in strong support of rule 10c-1, Reporting of Securities Loans. I believe that transparency within the stock market is deserved and would invite confidence within our markets. Rule 10c-1, Securities Lending Transparency proposed transaction-by-transaction reporting of all securities lending activity, every 15 minutes could be a monumental step in the correct direction. the cost and effort are justified to prevent fraud and prevent criminals from hiding in loopholes. With much ongoing speculation as to the extent of criminal and illegal ongoings within the US stock market, I hope that the SEC will do all that it can to ensure that investors within these US markets remain fully informed, assured and confident with their investments as held within the NYSE. This presents an opportunity for the SEC to provide a voice more powerful than their own for the small businesses, working families, and everyday people that are victimized by financial predators. This is also a great opportunity to give substance to the 'FY22-26 Strategic Plan for Public Comment.' With increased transparency, investors will have a much better idea of the risks of their decisions and transactions if they can see who is targeting which companies. If funds are allowed to short in the dark, retail investors remain dangerously unaware of the risks they take on when purchasing securities. More timely reporting allows for more timely reactions slower reporting prevents retail investors and working families from protecting themselves from abusive and predatory short-selling practices. Working families and individual investors need to be able to look both ways before they cross Wall Street. No one wants working families to get run over in the name of superior returns for hedge funds. In addition, victimized companies need a greater ability to defend themselves against predators. Short selling without transparency harms true competition and price discovery, and the idea that a small number of short-selling funds 'know best' and can hammer unsuspecting companies in the dark is shameful. Secret short selling hurts companies as well as individual investors in the name of greater profits for hedge funds. Timely detection of fraudulent and abusive activity should come before Wall Street profiteering. A short seller is not an investor, but the opposite. At the moment, it seems that The SEC prioritizes hedge fund comfort and profiteering over investor protection and market transparency. While short sellers might be afraid of short squeezes that can follow the identification of their short-selling strategy, that is not a reason for the Commission to decide against greater transparency. If abusive short selling is disincentivized, then short squeezes and dangerous volatility becomes less common. Sophisticated investors will quickly learn to avoid positions that could result in such dangerous volatility, which will benefit the market overall. Long, untracked lending chains lead to economic fragility, and securities lending activity can hide massively destructive chains of obligation that can even be a threat to national security, so transparency in this area is more important than it has ever been. The risks associated with reckless securities lending and short selling - highlighted with terrifying clarity following the events of Jan 28, 2021, go far beyond any theoretical benefits of secret short selling for superior returns. Investor protection comes first. The enactment of this rule would also introduce the ability for the general public as well as public companies to serve as watchdogs for the SEC as an initial line of defense against abusive practices, by being able to more granularly monitor short selling for securities fraud for those securities they are invested in, helping and strengthening the SEC's ability to fulfill its mandate and to help weed out market participants that are working against SEC rules, all at no additional cost to the SEC. I am a strong supporter of transaction by transaction reporting. It is clear that aggregated reporting is not transparent and provides far too much rope where fraud can be hidden in aggregates. Why should one individual or entity have to suffer a worse execution whilst another individual or entity benefits from a better execution, just because it is more convenient for certain institutions to report their short selling practices in the aggregate? It is wholly unfair and contrary to the requirement of best execution and so it should be a mandated requirement for transaction by transaction reporting. Sincerely, A Concerned Investor