Oct. 31, 2022
October 31, 2022 Securities lending without per-transaction reporting prevents market efficiency and actively damages investors. The ability of institutions to lend securities without reporting enables the creation of dangerously leveraged positions. The lack of transparency in securities lending also leads to a peculiar situation where beneficial holders of securities are able to undertake actions that are against the best interests of the investors on whose behalf they are supposed to be acting. Furthermore, a lack of reporting in short-selling contributes to an environment that is hostile to companies and their investors by preventing true price discovery. The implementation of reporting requirements for securities lending is essential for efficient markets. The 15-minute reporting requirement is a necessary step to protect companies and investors from predatory behavior, fraud, and price manipulation. I further support the implementation of per-transaction reporting of securities lending.