Aug. 9, 2024
Dear Security Exchange Commission, I’m writing as an individual investor to express my strong support for the proposed FINRA Rule 6500 Series, which requires reporting and public sharing of securities lending information. The Managed Funds Association (MFA), which represents many fund managers, has raised concerns about these rules. They suggest limiting transparency to what the SEC mandates, fearing that too much information could harm investors and market liquidity. However, I believe that broader transparency is crucial for a fair market. It levels the playing field by helping all participants access important information, leading to better price discovery and lower monitoring costs. The MFA also worries that revealing detailed loan information could discourage market participation by exposing short sellers' strategies. I disagree. I think this transparency reduces systemic risks and helps all investors understand the terms and risks of securities loans, contributing to a fairer and more orderly market. I’m concerned about the provision allowing FINRA to suspend reporting in certain cases. This could undermine the transparency that the rule aims to achieve and create an unfair advantage for some market participants. It’s important that any suspension of reporting is used sparingly and with clear justification to maintain the benefits of transparency. The requirement to report detailed data like the security issuer’s name, transaction dates, and loan amounts is essential for keeping the market fair and competitive. This information helps all investors make informed decisions. In conclusion, while I support FINRA Rule 6500 Series for promoting transparency and protecting investors, I urge careful control over any suspension of reporting requirements to ensure these goals are not compromised. Sincerely, Bliaxu Lo A household investor