Subject: S7-18-21: WebForm Comments from Sam S
From: Sam S
Affiliation:

Oct. 29, 2022



October 29, 2022

 RE: File Number S7-18-21
29 October 2022

Securities lending is perhaps the second largest issue that needs to be fixed immediately. I agree with the proposal, however I would like to be clear, I believe more needs to be done.

Securities lending enables the multiplication of shares in circulation. Unbeknownst to the retail investors, brokers are currently 'stealing' the shares held by retail investors and replacing it with an IOU to be lent out for brokers own personal gains. You can argue that they agreed to this if they chose to use the broker, but let's be real, that's balderdash.

The only folks who agree are the ones that make money of this practice and that are shorters, brokers, and the market maker. This practice hampers true price discovery. How can we know what the true price is when the number in circulation is extremely higher than shares outstanding, some over 10x? If a retail is holding their shares in the long term, and the broker lends their shares out to be shorted, I doubt the retail investors would agree to that. Securities lending ignores the investor's right to vote and receive tax-qualified dividends.

I support transaction-by transaction reporting. I support the 15 minute reporting requirement. The SEC needs to stop prioritizing wall street comfort over the profiteering of investors. The Dodd-Frank Act directed the SEC to seek transparency for brokers, dealers, and investors. Brokers and dealers have enjoyed all the  benefits at the expense of investors. I hope the SEC finally has the courage to do what is right and help retail investors.