Oct. 30, 2022
October 30, 2022 I would like to comment on this proposal, I dont feel it covers enough or does enough I would like to see the following in respect to securities lending: 1.) I want to see reporting of ALL POSITIONS AND LOANS every 15 minutes. Every position( long, short, derivative, swaps) report any position in any direction in any market using any means to profit from any movement in any security. Period. If something is used to profit or hedge from movement or non movement of a security or asset it should be reported. Also every loaned or borrowed security/asset should be reported with minimum of total availability, who borrowed, how many, when due back. 2.) I want to see detailed tracking and traceability of all securities and assets loans and positions used to profit in the capital markets including but not limited to: - what security - how many - From where/who - To where/who - Due date of loan - Revenue of loan 3.) I want to see a limit placed on the lending of securities/assets. No security/asset should be loaned more than one time. And the buyer of a loaned security/asset should be made aware they have bought a loaned security/asset and are unable to loan it themselves. 4.) for retail accounts who hold street name shares in brokerage accounts, I want to see them Given the option to opt out of lending their individual fully paid for assets/securities and be able to track and trace in some fashion to prove their assets/securities are not being lent out. 5.) I want to see full detailed disclosure about lending revenue and how its distributed, there should be a more equal split for the retail lending account and the broker facilitating the loan 6.) I want to see securities loans have termination dates or due date when everything must be returned and made whole again. Any cost associated with such regulations and reporting are nominal compared to the amount of capital at play in the US markets. If any such cost are incurred there is no reason it can not be figured in to the fees on the loan. If securities loan rules and regulation does not at minimum meet the above standards I dont see any reason to allow it. Concerned US Retail Investor