Subject: S7-08-22: WebForm Comments from M Truax
From: M Truax
Affiliation: Concerned Investor

Oct. 29, 2022



October 29, 2022

 Failure to delivers are constantly going undelivered with essentially 0 real consequences, the consequences are low enough to be considered a cost of doing business and it is beyond harming actual trade price discovery.

Short selling while intentionally FTDing is completely eradicating the definition of price discovery. There is no actual price discovery with the rules in place now, it just gets dismantled.

Below is an excerpt I completely resonate with.

The SEC website states that
 securities loans are transactions that are vital to fair, orderly, and efficient markets. This is
 simply not true. Securities lending enables the multiplication of shares in circulation. When
 brokers lend the shares being held for retail investors, for example, it is equivalent to
 replacing the bought and paid for shares with an IOU. Securities lending ignores the
 investors right to vote in matters of corporate governance and to receive tax-qualified
 dividends. Further, a fail-to-deliver (FTD) that is closed with a borrowed share is not really
 closed  it leaves open that IOU with the lender. Therefore, securities lending harms market
 efficiency by inflating the number of shares in circulation, which hampers true price
 discovery by artificially increasing supply.