Subject: S7-18-21: WebForm Comments from Thomas Tavenner
From: Thomas Tavenner
Affiliation:

Oct. 31, 2022

 


 October 31, 2022

 I firmly believe that the reporting of securities loaned be reported every 15 minutes as initially proposed. I believe that all positions, whether short or long be included in this reporting. To reiterate, SHORT POSITIONS on loan be reported in the originally proposed SEC Rule. For the sake of market integrity and national stability Rule 10c-1 must be passed as the SEC originally drafted, so that transaction-by-transaction reporting be enforced because it eliminates the ability to \"hide within the aggregate\" and aggregates are not transparent. There can be no fair and reputable market if transparency is not taken seriously, as there is no such thing as \"almost transparent\".

The FY22-26 Strategic Plan for Public Comment is a step in the right direction because the loaning of the working class Americans positions is jeopardized when our assets are being used in a predatory nature by shares on loan without our knowledge or consent. This predatory nature I speak of is loaning shares to short sellers that are not using those shares for the betterment of those companies, short sellers are not investors If I believe in a company, buy stock, then those shares are lent out to an institution betting against the company I am putting my families limited wealth and future into, than my investment is literally under attack. The instability and volatility the markets saw during the Jan. 2021 \"meme stock\" craze was predominately made possible due to short selling, and with greater transparency on shares lent, those volatile moments become much less frequent, thus stabilizing our markets.

The Meme Stock squeeze episode did however have a sort of black swan effect in that it gave rise to the public looking into short selling activity, highlighting potential for fraud and has created several investor communities that have now taken it upon themselves to be \"watchdogs\". However, in light of that, these communities are very much so weary of US markets and can have a significant impact -whether positive or negative - on market engagement and trust. With increased reporting requirements and transparency of shares lent out, it gives the public access to data that can be used to protect themselves.

The dangers of un-reported lending requirements, or the delay of reporting raises opportunities for lending, on top of lending on top of lending to the point that tracking lent securities becomes so obscure that the obligations become troublesome for market stability.

If the SEC has the best interests of the American people in mind, they would do well to rememberer that the Dodd-Frank Act directed the SEC to seek transparency for brokers, dealers, AND
retail investors. S7-18-21 I believe would uphold the SECs integrity by passing it the way it was originally drafted.