Oct. 31, 2022
October 31, 2022 Short positions should ABSOLUTELY not be excluded from the Proposed Rule. Full stop. There is absolutely no reason why securities lending should be reported every 15 minutes. Beyond the fact that this allows everyday retail investors to determine full disclosure of how their securities are lent (many of whom sign up to these with nary much guidance about what is happening), it will give these individuals continued faith in the use of their securities as needed. Transaction-by-transaction reporting is absolutely necessary. It helps to avoid unforeseen events--such as the large naked short positions taken by parties against Bear Stearns--where individuals were unable to see just how their own shares not only forced this company to fall but also ignited a financial catastrophe worldwide. Correct hyperbole aside, this truly protects citizens from being pushed into agreements where they truly are not aware of how their shares are being used. Retail benefits from this transparency, whereas it is in the best interest of market-makers, hedge funds, and other parties to obscure this information from the greater public. Long, untracked lending chains are dangerous. One can see, for example, how many stocks that eventually go bankrupt (such as Sears) encounter high short interest prior to their bankruptcy. How is a retail investor to know that there isn't the chance that a Sears employee with stock in their company--engaged in securities lending--has their stock illegitimately Xerox'ed to naked short their own company? The way out is public disclosure, which is so desperately needed. This needs to be done and pushed for immediately. Short positions should NOT be exempt. Full stop.