Aug. 21, 2023
Dear Ms. Countryman: I support the implementation of this proposal in it's written form immediately. Transparency with position in security-based swaps is long overdue. Money market funds are required to prepare a form on their portfolio quarterly and given 2/3 of the next quarter to file it and shows positions and issuer on the repo data. The managed and private fund are required to file 13Fs quarterly in similar format, banks and other financial institutions, file an Information Table on positions in publicly traded issues. As you know, there are numerous inter-institution arrangements and arranged borrows in these publicly traded issues (it is viewable in the number of shares that have voting authority - in the Information Table of each 13F). Hedge Funds are not just any other institution by the number of leveraged strategies at their disposal. Among managed funds with hedge strategies, larger ones are sponsored or approved for dealing in repurchasing arrangements with Federal government and agency securities. These issues are considered prime collateral for structuring repurchasing arrangements and swaps. Such as money market funds should disclose a snapshot of their counterparties and issues with the terms of the yield and maturity, along with the collateral, so also should these Managed Funds with greater than peripheral dealings with swap-issuing subsidiaries of banking institutions considered too big to fail. This rule change will provide a snapshot to further understanding of the relationship between security lenders and borrowers. I support this proposal for improvement of the disclosure with securities lending whether it be arranged between two counterparties or whether it is a tri-party arranged agreement. A Concerned Household Investor