Oct. 31, 2022
October 31, 2022 I support the passing of rule S7-18-21. This rule is a start. Securities lending as it currently stands is in absolutely atrocious condition, such as the fact that a \"reasonable locate\" is all that is required. The fact that operational short selling for liquidity exists at al is baffling, given that liquidity at various prices is the whole price selection mechanism of markets to start with. Price too high, no buyers, price falls. Price too low? No sellers, and the price rises. Price discovery is the whole point of a market, liquidity is just a number that is partially derived from the price. It should not be a determining factor of the health of the market. The fact that nobody can seem to tell just how many rehypothocated shares from short positions, swaps, and various other tools that are floating around should be a glaring signal that more robust, real time, and ideally trust less reporting of securities lending is necessary in the largest financial market in the world. To take the securities lending market reporting question to the rational conclusion, exactly what utility is exactly provided by the existence of securities lending in it's entirety, if looked at from a holistic perspective? In the commonly quoted \"It is checks and balances for fraud/overpricing\