Oct. 08, 2022
October 8, 2022
October 8th, 2022
Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609
Re: Reporting of Securities Loans (File No. S7-18-21)
Dear Secretary Countryman,
I am writing in strong support of rule 10c-1.
Rule 10c-1, Securities Lending Transparency proposed transaction-by-transaction reporting of all securities lending activity, every 15 minutes.
I believe that transparency like this within the stock market is deserved to all investors and would promote confidence within our markets.
When short selling practices occur in the dark and short sale information is provided long after a position has been entered into, retail investors (and the like) cannot be aware of the risks that they take on when buying securities. You can understand why this lack of information would represent a problem for all investors, who are expected to invest on incomplete and dated short sale information. I strongly support the intraday 15 minute reporting requirement. The cost and effort involved with this is justified to help in early identification of abusive shorting practices, to reduce the ability of toxic market participants to hide behind loopholes and to attempt to prevent such fraud occuring in the capital markets.
The new rule would also provide any victimized companies a greater ability to defend themselves against predatory short selling, as short selling in the dark harms true competition and price discovery. Why should select investment firms decide the fate of a company versus the retail investors/patrons of a company? Especially in situations where they represent the vast majority. Pooled money from the elite few (Short Hedge Funds/Market Makers) must not dictate a companys future. Instead, let the support of the investing public (or lack thereof) and a companys fundamentals decide. The enactment of this rule would also introduce the ability for the general public as well as public companies to serve as watchdogs for the SEC as an initial line of defense against abusive practices (clearly the institutions abusing these practices do not monitor themselves), by being able to more granularly monitor short selling for securities fraud for those securities they are invested in. In turn, helpi
ng and strengthening the SEC's ability to fulfil it's mandate and to help identify market participants that are working against SEC rules.
I am a strong supporter of transaction by transaction reporting. It is evident that aggregated reporting is not transparent and provides far too much rope where fraud can be hidden in aggregates. Why should one have to gamble due to this clear and present disadvantage, while another benefits from a better execution, due to these advantageous institutions/investment firms whom report their short selling activity in the aggregate, clearly only benefitting them and their involved parties who take full advantage of these unfair/unjust practices (usually at the expense of the disadvantaged investors)? It is an understatement to say that its unfair to most, and contrary to the requirement of best execution. Rule 10c-1, needs to be a mandated requirement for transaction by transaction reporting as a step in the right direction towards creating a free and fair market for all investors.
Sincerely,
A Concerned Investor