Subject: S7-18-21: WebForm Comments from Helmut Herglotz
From: Helmut Herglotz
Affiliation:

Oct. 31, 2022

 


 October 31, 2022

 Thank you for the opportunity to comment on 7-18-21 (Reporting of Securities Loans).

As a retail investor, the security lending market is a market that I do not engage in directly, but one that has a very strong impact on my investments. Securities lending is regularly the reason that retail investors are not able to execute their right to vote, as well as receiving actual dividends (and not just payment in lieu).

I personally have been in the situation that I was not able to cast my vote as a shareholder. If this was due to share lending, I believe this should be transparent information, available to investors.

The market needs to know who is actually lending shares to whom.

It should be transparent and possible to track securities that have been lent out.

Multiple onward lending (e.g. rehypothecation) is something that I do believe is not in the interest of retail investors and should be forbidden.

Thank you very much