December 4, 2021
I support the SEC's efforts to promote transparency in the \"lending\" of securities (short selling).
Real reform for securities lending must include:
1- Daily public publication of who is
borrowing lending shares (not just
which companys shares are borrowed or
lent)
2- Investors must be notified immediately
if their shares are lent.
(a)they lose their right to vote
(b)they don't get tax-qualified dividends
3- Any revenue generated from lending must
be shared with the original investor.
4- Eradicate Onward Lending completely.
(This has been opposed for decades by
transfer agents and public companies)
5- All loans must have a hard due date,
not \"if applicable\".
Finally, it seems likely that Proposed Rule will increase cost and reporting burden of borrowing stock for any reason (cover short sales, close fail-to-deliver, access voting rights, etc.). Unintended consequence may be to tilt brokers cost/benefit analysis in favor of fails.
Thank you for your time.