Oct. 31, 2022
October 31, 2022 RE: File Number S7-18-21 As an investor, I am committed to participating in markets which are free and fair. The Dodd-Frank Act directed the SEC to seek transparency for brokers, dealers, and investors. Whilst supportive of any rule which facilitates transparency, I do not feel that this rule goes far enough in its proposals. In addition to the current plans, I ask that the following provisions are considered: 1. Clarity on who is borrowing and lending shares (rather than just which companys shares are being borrowed or lent). 2. Notifying retail investors with street name shares that their shares are being lent (many are not aware of this). 3. Eliminating the practice of Onward Lending completely. As it stands, the disclosure of lending inventory and near-real-time position reporting will only make it possible for broker-dealers to discriminate against companies who are already bearing an onslaught of phantom shares in capital markets. Best Regards, FW