Subject: S7-18-21: WebForm Comments from Zach
From: Zach
Affiliation:

Oct. 30, 2022

 


 October 30, 2022

 I believe we should require quick and accurate reporting on all securities lending related actions. Transaction-by-transaction reporting would hinder the ability to hide lending in the aggregate, undermining transparency. The 15 minute reporting requirement is also a great idea, and well worth the effort to keep our markets fair and transparent. The ability to lend securities puts the integrity and safety of our markets in jeopardy, as it allows for the creation of makeshift and additional securities. Companies have become the target of some of these harmful practices, and by and large have not been able to defend themselves properly. Proper reporting of this data would be the first step in allowing them to fight back against oppressive lending practices.

The ability to short sell is not the ability of an investor, but someone who will take away and erode our markets. Securities lending makes this ability possible, and should be reported much more frequently and accurately if we hope to entice and keep retail investors involved in our markets. Long, untracked and unreported lending chains have the potential to cripple our markets when exposed, and we must not allow them to go on any longer. Doing so would be looking the other way while our everyday investors are blindsided by more profiteering from the big players.

We are in a very special situation currently, where for the first time, retail investors are stepping up and becoming front-line watchdogs. I ask that the SEC help enable these retail investors by facilitating stringent and proper reporting of securities lending, and publishing of the reportings publically.

Thank you for the continued effort to keep our markets safe and fair, I hope this proposal will pass quickly and with the average investor in mind.