Subject: S7-18-21
From: Andres Loubriel
Affiliation:

Dec. 16, 2021

The securities lending process feels to me a mechanism that corporate traders can use against retail. With a lack of transparency into swaps and FTDs, there are far more things at play than a free fair market. 

I will cite below bullets from Dr. Susanne Trimbath on reform. 

(1) Notifying public about who is borrowing & lending shares (not just which company’s shares are borrowed or lent), 

(2) Notifying retail investors that their shares are being lent, (because (a) they don't get to vote & (b) they don't get tax-qualified dividends) 

(3) Sharing any revenue earned from lending their shares with retail investors 

(4) Eliminate “Onward Lending” completely (public companies & transfer agents have opposed this for decades) 

(5) Require every loan to have a due date (not “if applicable”)