Nov. 01, 2022
Hello SEC, Securities lending is a big part of how the market functions as of right now but due to this, failure to delivers are at an insane level aswell. A long, unkept track of lent securities with lead to a false market where participants aren't required to purchase securities when they should have. This hurts investors investments and their trust in the markets that they had sought to believe was fair, when in fact other participants have different and more advantageous rulings and exemptions due to their status. In order to make transactions flow correctly, transaction by transaction reporting should be put in place. This will keep transparency at the front door where it belongs, no longer with hidden data. This should also be paired with timely and accurated reporting, in a 15 minute window. In a perfect system, it would be in real time as I have discussed in other comments. I would like to point out that liquidity is no use when it doesn't flow into the correct places it should do. If lent securities are used in order to satisfy a failure to deliver or short position then it continues to be a free market but not in the sense that the SEC may recognise it as, but a wild west outlaw free market where criminal activity is occurring and stealing money from others is OK as long as you can fake a purchase. I would also like to say that I'll be making a formal complaint with the SEC over their poor workplace procedures, such as losing public comments for proposed rulings. With something as large and important as the US markets, comments on rules and regulations for them should be of the utmost importance. Working in the IT field myself, I know that either the SEC has nowhere near the proper standard of technological backups used in a government and financial regulatory body or that the comments were purposefully erased. I hope my comment is read well and positive changes are made. Yours sincerely, Jack. International investor.