The following Letter Type E, or variations thereof, was submitted by individuals or entities.

Letter Type E:

August 7, 2024
Via Electronic Mail: rule-comments@sec.gov
Vanessa A. Countryman Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090
Re: File No. SR-FINRA-2024-007 (Release No. 34-100046)—Securities Lending and Transparency Engine (SLATE) Rule 6500 Series
Dear Ms. Countryman,
As a retail investor, I strongly support the proposed SLATE Rules and believe they are crucial for ensuring a fair and transparent market. The Managed Funds Association (MFA) raises concerns primarily about the negative impacts on short selling and the potential disclosure of confidential trading information. However, these arguments overlook the substantial benefits that increased transparency brings to retail investors like myself.
1. Market Fairness and Transparency: The proposed SLATE Rules would significantly enhance market fairness by providing greater transparency in securities lending. Retail investors often find themselves at a disadvantage due to the lack of accessible information. By mandating detailed disclosures of securities loan transactions, the rules would level the playing field, allowing all market participants to make more informed decisions.
2. Prevention of Manipulative Practices: Greater transparency in short sale information is essential to prevent market manipulation. The events surrounding GameStop and other "meme stocks" in early 2021 highlighted the vulnerabilities retail investors face due to opaque short selling practices. By requiring the disclosure of detailed loan transaction terms, the SLATE Rules would help identify and deter manipulative activities, protecting retail investors from potential market abuses.
3. Enhancing Investor Confidence: Retail investors deserve to know the true dynamics of the market, including short selling activities. This information is critical for assessing market sentiment and making informed investment choices. The proposed rules would foster greater trust and confidence among retail investors, encouraging broader participation in the financial markets.
4. Aligning with Regulatory Goals: The MFA’s concerns about the potential chilling effect on short selling overlook the SEC's historical recognition of the positive impacts of transparency on market integrity. The SEC has long advocated for measures that promote transparency and protect investors. The SLATE Rules align with these objectives by ensuring that critical information is publicly available, thereby supporting a more robust and transparent market.
5. Protecting Small Investors: Large institutional investors and hedge funds have access to sophisticated tools and information that retail investors do not. The proposed SLATE Rules would help bridge this information gap, ensuring that all investors, regardless of size, have access to the same market data. This is a fundamental step towards protecting the interests of small investors and ensuring a fair market environment.
In conclusion, the proposed SLATE Rules are a necessary and overdue step towards enhancing market transparency and fairness. Retail investors have the right to see detailed information about short selling activities, and such transparency will ultimately lead to a healthier and more equitable market for all participants.
Sincerely,
A Concerned Retail Investor