November 25, 2021
To whom it may concern,
Real reform for securities lending must include:
(1) Notifying public about who is borrowing & lending shares (not just which company’s shares are borrowed or lent),
(2) Notifying retail investors that their shares are being lent, (because (a) they don't get to vote & (b) they don't get tax-qualified dividends),
(3) Sharing any revenue earned from lending their shares with retail investors,
(4) Eliminate “Onward Lending” completely (public companies & transfer agents have opposed this for decades),
(5) Require every loan to have a 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 broker’s cost/benefit analysis in favor of fails.
Sincerely,