Subject: S7-18-21: WebForm Comments from Sherwin D'Souza
From: Sherwin D'Souza
Affiliation:

Oct. 31, 2022

 


 October 31, 2022

 I am absolutely for this proposed rule, but I think more things should be done to make the market safer for all investors.

Security lending is not vital, orderly and efficient for the markets.  This allows the multiplication of shares which causes basically failure-to-deliver shares. It basically prevents true price discovery in
regards to equities.  Basically security lending prevents true price discovery and shafts the owners of companies, and investors.

How is it possible that shares lent out, can continue to have no expiry date. The market makers and banks can continue
to roll their failures to deliver to another future date, without any transparency and without repercussions.

This proposed rule does not go far enough to  solve voting rights and transparency for investors.


This can not continue, because it impacts greatly the companies on the stock market, in that the value of their company
is reduced in value, because of organizations shorting the company, with synthetic shares, and no transparency when those shares will be
bought or returned to the market.

The companies can not receive additional capital, or if they can they will pay on their loans at higher interest rates.  This is certainly not the fault of the company,
but rather the vultures who are preying on these companies by borrowing shares, and shorting the company.  The vultures
continue to shift their position by either borrowing more shares and covering their Failure to Deliver, or they make deals with
banks/market makers and cover their crime by executing swaps, which again are also not transparent.

I welcome the proposed rule, but the SEC should do more to stop phantom shares.