Subject: S7-18-21: WebForm Comments from BRENTON CARLING
From: BRENTON CARLING
Affiliation: NIL

Oct. 30, 2022

 


 October 30, 2022

 To Whom It May Concern,

My name is Brenton Carling and I am a small investor in US securities, and also hold US securities in my self managed retirement fund.
Firstly I want to declare that i am amazed beyond comprehension as to why all securities that are lent, created or sold have no identification number. Cash notes have Identification numbers to prevent fraud, and i believe it is imperative that the SEC should be aggressively lobbying the US Government to have a unique ID number attached to every security that is issued, to enable tracking, and hard locate of securities during the lending process. There is no other industry in which anything of value is lent without a due date for its return. Why is securities lending different ? None of this would be an issue if Broker dealers and banks kept track of whose shares they were lending. I understand that this would require a massive market restructuring, so in lieu of that, it is an excellent rule proposed by the SEC to record the transaction by transaction reporting of all securities lending, every 15 minutes. I also believe this rule should cover pre market, and after market lending acti
 vities. These markets exhibit extraordinary trading patterns, and are the domain of market making firms, and other institutional insiders, where the activity is unknown to a regular investor.
I explicitly support the SEC and the proposed 15 minute transaction by transaction reporting because it eliminates the ability to \"hide within the aggregate\