Subject: S7-18-21: WebForm Comments from Brandon G
From: Brandon G
Affiliation:

Oct. 31, 2022

 


 October 31, 2022

 Good Afternoon,


I am in favor of the proposed rule. I think we can take it a few steps further to further ensure a safe and fair market for all.

First of all securities loans are not transactions that are vital to fair, orderly, and efficient markets.  Securities lending enables the multiplication of shares effectively artificially increasing supply and therefore diluting the value of the stock price that the original investor bought stock in.

Securities lending harms the market by depressing price discovery especially when there is no due date or return date. There should be a limit on how long a share can be on loan. Shares should not be able to be borrowed to cover a fail to deliver either. We should be thinking about protecting investors and providing a fair market for everyone. The proposed rule does not include who is actually borrowing or lending the shares and whoever actually owns those shares ie the retail investor should be notified, as if they knew their shares were being lent out to short a stock they would be very upset. Why does the retail investor not receive any of the lending fee for their shares being lent out to others? The retail investor here is getting the worst of both worlds. 1 Their investment is being diluted, so its likely the stock goes down, 2 they are not receiving any lending fees. Loans should have due dates. The 15 minute reporting requirements are a good start it is a good idea to prevent
  fraud and abuse.

We need to have transaction by transaction reporting to have market transparency.


Many of the opponents of this regulation say that reporting data is too expensive, this is not the case. The only people who lose from reporting data are the people that are currently abusing these loopholes.

Thanks for you time, I know the The purpose of the SEC is to protect all investors and hope that the SEC will continue to adopt rules that work and contain the backbone to enforce all market participants to play on the same playing field.