Aug. 9, 2024
I am writing to express my general support for the proposed FINRA Rule 6500 Series, which mandates the reporting of securities loans through the Securities Lending and Transparency Engine (SLATE). Increased transparency in the securities lending market is essential for maintaining a fair and orderly market, improving price discovery, and protecting investors. I commend FINRA for taking steps to address the information asymmetry that has historically disadvantaged end borrowers and beneficial owners. The comprehensive data elements required to be reported, including issuer legal name, LEI, security symbols, transaction details, and collateral information, will significantly enhance market participants’ ability to make informed investment decisions. However, I have reservations about the provision allowing FINRA to suspend reporting or dissemination of certain data. While I understand the need for flexibility in some circumstances, it is imperative that such suspensions be exercised judiciously and with rigorous justification. Unnecessary suspensions could undermine the core objectives of the rule and create new opportunities for market manipulation. To fully realize the benefits of increased transparency, it is crucial that the rule be implemented with a strong emphasis on consistent and timely reporting. I urge FINRA to adopt clear guidelines for the suspension of reporting and to provide detailed explanations for any such actions. Thank you for considering my comments. Sincerely, A Household Investor