Subject: S7-18-21: WebForm Comments from Bamlak Tilahun
From: Bamlak Tilahun
Affiliation: NA

Oct. 31, 2022

 


 October 31, 2022

 A broker's ability to lend shares without the retail owner's awareness goes against the investor's interests. These lent shares could be used to create new short positions or to roll over FTDs. A share should not be lent out without the consent of the owner. Covering FTDs is not a good enough excuse to utilize this mechanism as FTDs shouldn't even exist to this level as that's basically selling what you don't have under false pretense (AKA: Theft). Retail should be aware of how their rightfully owned shares are being used and this comes with providing transparency on what shares are being lent, the quantity, time of the transaction, and the parties involved.