January 7, 2022
I agree with Dr. Trimbath that this proposed rule doesnt address the root issue at the heart of securities lending: it harms market
efficiency by inflating the number of shares in circulation, which hampers true price
discovery by artificially increasing supply.
Without significant consequences for missing reporting deadlines, marking of securities lent, the prohibition of re-lending marked securities, and the public disclosure of who is borrowing the securities, this rule will be ignored like so many others whose fines are accepted as a cost of business.
We have blockchain technology today that could efficiently automate the tracking and reporting of securities without the overhead, propensity for human error, and susceptibility to fraudulent activity of another reporting agency. Perhaps we should start there to address the root issue.