Oct. 31, 2022
October 31, 2022 To whom it may concern, as an long time international individual investor in different stocks of the US market I want to express my support for the proposed rule Reporting of Securities Loans (File No. S7-18-21). The trust in the US market should be based on the necessary transparency in terms of data and price discovery. Requiring publicly disclosed transaction-by-transaction reporting allows for said transparency, such that all investors in the US market can be aware of risks associated to trading of specific securities. This allows a fair market for all participants. While reporting of short data allows domestic and international companies to engage predatory short selling, reporting of (excessively large) swaps can reduce threats to financial and national stability. Therefore, the threshold for required reporting should be lowered to $100 million gross value. I agree with the definition of security-based swaps and want to emphasize, that a wide definition of security-based swaps is required to reduce evasion. For the same reason, international application of the proposed rule to avoid evasion concepts would be welcome by myself. Enforcing short as well as swap reporting on a transaction-by-transaction level empowers individual market participants, e.g. retail investors, to protect themselves from unknown excessive risks. A more level investing environment, as created by this rule, is absolutely in the public interest and reduces potential damage to financial and national entities caused by excessive swap activities. With publicly disclosed reporting as stated in the proposed rule, a wider range of market participants can observe potentially dangerous or fraudulent market activity and thereby support the Commission, as the general resources of the SEC are limited. Overall I want to express my full support for the proposed rule and ask the SEC to finalize and install this rule as soon as possible. Best regards Reinhard Weber