Jun. 12, 2024
Dear Securities and Exchange Commission, I am writing to express my serious concerns regarding the delay in the approval of File Number SR-FINRA-2024-007, which mandates the reporting of securities loan modifications. The proposed rule requires reporting critical data points such as: - The unique identifier assigned by FINRA or the unique internal identifier assigned to the Covered Securities Loan. - The unique internal identifier for an omnibus loan if applicable. - The MPID of the Covered Person. - The date and time of the Loan Modification. - The expected settlement date for modifications to the loan amount or the effective date for all other Loan Modifications. - The role of the Covered Person (lender, borrower, or intermediary). - The modified Data Elements or all Data Elements for a Loan Modification not previously required to be reported. - Required modifiers and indicators as per Rule 6500 Series or SLATE Participant specification. The delay in approving this rule is unacceptable for several reasons. First, it provides wrongdoers more time to exploit gaps in the current reporting framework, potentially engaging in financial crimes undetected. Such activities can lead to significant financial losses and undermine the integrity of the securities lending market. Furthermore, the lack of timely and accurate reporting hampers the ability of regulators to monitor and address irregularities in the market. This gap in oversight can erode investor confidence and destabilize market conditions, making it more difficult to maintain market stability. Timely approval and implementation of File Number SR-FINRA-2024-007 are essential to enhance market transparency, deter financial misconduct, and ensure a robust regulatory environment. I urge the SEC to prioritize the approval process for this rule to safeguard the interests of all market participants and uphold the stability of our financial markets. Thank you for your attention to this critical matter. Sincerely,