Subject: S7-18-21: WebForm Comments from John Jacob Jingleheimer Schmidt
From: John Jacob Jingleheimer Schmidt
Affiliation: Electronic Technician

Oct. 30, 2022


October 30, 2022

 Transparency is always the best option if you intend to (at some point) regulate a free and fair market with actual price discovery.  At the moment, the market is plagued by rehypothecation, phantom shares, FTDs, etc.  These are problematic to the stability of the market.  If we can get frequent reports on lending we can see who is resetting FTDs with borrowed shares. Potentially see who is continuously lending out the same shares over and over again.  Or which brokers are lending street name shares without the knowledge of retail investors. Lending and borrowing shares is NOT vital to a market. If there is a high demand the price should rise enough to find a seller.  That's how REAL markets work.

If financial institutions have nothing to hide, then they shouldn't have an issue with this rule.  If they are lending so many securities that they feel reporting is an issue then maybe, we should be looking at where these securities are coming from, retail investors or thin air for example.