Oct. 29, 2022
October 29, 2022 The lack of transparency for Securities lending seems to be a very large contributor to the intentional FTD issues destroying the chance at a free OR fair market. Price discovery has been absolutely decimated directly from securities lending leading to FTDs. More transparent reporting is a must to even remotely curb whats currently happening to the individual investor, it truly should be finalized and implemented immediately as possible. Lending shares of investors shares in general, but especially the lending of shares without the investors knowledge is being abused by willing rule breaking participants on a daily. Lending of shares DIRECTLY hurts the individual investors investment, all while helping the brokers, market markers, broker dealers, rule breakers, and rule benders line their pockets with individual investors money. Lending of shares with or without the investors knowledge is very harmful to the free market. Lending an investors shares can only be used for a few things, NONE which help the investors actual investment. Short selling, diluting floats, diluting the price of investment, FTDS, watering down investments by adding fake non issued shares into the market, etc in reality of todays markets ONLY allows the investment to go DOWN IN VALUE. AT NO POINT does the excessive lending of shares EVER help the investment the shares are being lent from, grow It can ONLY negatively impact that investment FOR THE ACTUAL investor of that underlying security. It only has the potential to negatively effect that investment its being lent from. More mandatory reporting will help a bit, but even after this proposal gets implemented, more needs to be done about the actual abuse on the extreme scale thats happening. Thanks for this proposal, but please DONT STOP HERE it needs to undergo even further changes or action to the reality of whats happening to the value of investments EVERYWHERE directly from what seems like just simple share lending. More action is needed beyond this proposal, so the sooner this is finalized and implemented, the sooner more action can happen. This proposal might minorly ease up the flow of the extremely harmful crime sprees taking place in our markets now, but the absolute majority of it needs to be stopped immediately, and this proposal is a footstep in the correct direction. I could not agree more with Dr. Susanne Trimbath. Below is a small piece I completely agree with. Truly, she should be in a position to directly help the SEC or even work high up for the SEC as it is completely apparent she has no addenda and just straight lifetimes of knowledge in what the SEC does or is suppose to be enforcing. Its not a dig at you, as Im not sure what the real hurdles are from holding back enforcement, but if there is remotely any doubt or help it would be extremely wise to contact her for information or assistance. Absolute gem of knowledge with an actual will and want to help others understand whats really going on within the markets. Knowing how to ACTUALLY make the markets free and fair like they were designed to do in the first place all starts with understanding, stopping/eradicating the foul players, and enforcing the rules in order to show the next man what happens if they break the rules. Right now, breaking the rules is just a cost of business, and the c ost of business is a fine for a FRAAAACTION of sheer profits made by the rule benders and rule breakers. THERE IS ABSOLUTELY NO INCENTIVE FOR THE RULE BREAKERS TO STOP BREAKING THE RULES The fact sheet from the SEC website states that: securities loans are transactions that are vital to fair, orderly, and efficient markets. This is simply not true. Securities lending enables the multiplication of shares in circulation. When brokers lend the shares being held for retail investors, for example, it is equivalent to replacing the bought and paid for shares with an IOU. Securities lending ignores the investors right to vote in matters of corporate governance and to receive tax-qualified dividends. Further, a fail-to-deliver (FTD) that is closed with a borrowed share is not really closed it leaves open that IOU with the lender. Therefore, securities lending harms market efficiency by inflating the number of shares in circulation, which hampers true price discovery by artificially increasing supply.