Jun. 12, 2024
To whom it may concern, As a Canadian investor in the U.S. market, the delay in implementing SR-FINRA-2024-007 raises significant concerns about the legitimacy and transparency of the US market. It is evident that the so-called "Self-Regulatory" Organizations are more concerned about the continued profits of their members, using any means necessary, at the detriment to household investors. Here’s why this delay is worrisome: Transparency Issues: This rule is designed to make securities lending more transparent by requiring comprehensive reporting. Any delay means crucial information about securities loans remains hidden, making it difficult for investors like myself to make well-informed decisions about investments in the U.S. market. Legal and Fair Trading Concerns: Without the implementation of this rule, there's an ongoing risk of information imbalances. Larger institutional investors will continue to have access to more detailed information than individual investors, creating an unfair trading environment. This imbalance is a significant concern for ensuring legal and fair trading practices. Market Integrity: The rule promotes a fairer market by ensuring that all market participants have equal access to information. Delaying its implementation prolongs the current situation where some investors have an undue advantage, undermining the integrity of the market. Increased Risk: Transparency is crucial for reducing systemic risks within the financial system. Delaying this rule keeps these risks in play, potentially impacting the overall stability of the U.S. market and, by extension, the investments of foreign investors like myself. Investor Protection: The detailed reporting required by this rule helps protect investors by providing necessary information about securities loans. Without this information, investors are more likely to make decisions that could lead to financial losses, as they are not fully informed about the risks involved. In summary, I am deeply concerned that delaying SR-FINRA-2024-007 continues to compromise the transparency, legality, and fairness of the market, putting my investments at greater risk. Thank you. Michael MacPherson