Oct. 31, 2022
October 31, 2022 Dear SEC, I am writing to express my support for more transparency from financial institutions as it relates to securities lending practices. As a retail investor, I was personally aghast when I learned that my portfolio could be lent out (most commonly for short selling) against my will. This caused me to educate myself on this process in an attempt to more deeply understand the inner workings of securities lending. I fully support individual transactional share lending reporting as this methodology provides the most granular data and avoids obfuscation within the aggregate of all shares lended. This implementation would provide useful data for investors as we would now be able to on a security-by-security basis, which securities are being lent, by whom, to whom. This has extremely positive implications for all market participants and allows individual investors the data that they need to fully analyze their risk in any given position. I support the 15-minute reporting requirement as this forces securities lenders to be more transparent and arms the SEC with the data required to ensure enforcement. While the detractors argue that the cost and time to implement are not worth the return, I feel that both are justified to \"even the playing field\" for individual investors and their families. We are fighting an uphill battle when participating in the markets alongside firms with incredible leverage, technological and political advantages. I want to know if my owned securities are being lent to be sold short or cover a failure to deliver, both of which are counterforces toward my investments. I also want to have the detail to hold my brokers accountable and make informed decisions as to whom I engage in a client-broker relationship with. The Commission needs to ramp up support for both companies and their investors. By allowing securities lending data to remain opaque and non-descript, we are enabling predatory financial practices to continue to hamper companies' ability to innovate and grow. Short selling (arguably the most common use of borrowed securities) is anti-investing. The Wall Street firms that engage in this practice are often using it to destroy, rather than hedge. Yet they appear to whine whenever there is a risk to their bottom line. Please stop catering to them and enact this rule to prevent them from ruining more American business and families with this destructive practice. I applaud the SEC's efforts in proposing this rule and all the work that has been done by the Commission in the areas of furthering market transparency. Fair participation for ALL market participants and increased protection of public investors is paramount in this age of information. To allow brokers and market makers to evade the security lending reporting rules is an unfair practice that only harms the individual investor. If I believe in a company enough to own their shares, how is it fair for my broker to be able then lend my shares without my knowledge to be used against my portfolio? At least give me the data to see this practice in the light so that I can more accurately assess my own risk. Please proceed with the implementation of this rule ASAP.