Oct. 19, 2022
October 19, 2022 The Commission should exercise their authority to require persons that are not members of an RNSA to provide information to an RNSA, because no compelling case has been made for unevenly applying this rule across the market. The broadest impact of requiring securities lending is the reduction in the opacity of the market. I can't know if one of my long positions is itself shorting another of my long positions. I need that information so I can make a portfolio that isn't self-defeating. No lenders should be excluded from these requirements. Market participants shouldn't be held to different standards and public information shouldn't be riddled with exempted gaps. Yes borrowers should also be required to provide 10c-1 information in addition to lenders. While such a requirement may increase the overall costs and burden, not making fair rules because it's difficult is a sad and pitiful reason to exempt borrowers from their responsibilities in the market. This rule's scope should include all securities. Why would you cherry-pick any type of security lending remain opaque? How can the market be fair when the referees apply different rules to different participants? Government securities should not be excepted or exempted, because it results in purposeful opacity in the lendings market. Yes, the Commision absolutely should define what it means to \"loan a security\". For truly, how else could you even possibly know when this rule should be been obeyed but wasn't? The revelations on market opacity and the dearth of meaningful data from the private sector, these sections rang true for me. Absolutely the commision should also be provided all the same information as an RNSA. How else can the commision detect fraud unless they keep track themselves. How can the commision ever hope to ensure the rule is being followed if you never even look at the data? Is there any reason besides \"muh profits\" for the Commision to take their eyes off the hen house with these reporting requirements?