April 20, 2022
I believe the proposed rule changes should NOT be passed. These changes would only serve to protect institutions engaged in the practice of lending securities (on both sides) and that is not what the markets need. These protections give further incentive for lending securities, and would create even more risk in the long term - even though it may reduce risk in short term. We need more regulation in order to prevent opening positions that pose the risks outlined in the filing - not protections for those who took on those positions. Lenders, as well as borrowers, should be very aware of the risks they are taking on. This rule change would be going in the opposite direction of healthy markets and should not be passed under any circumstances. Thank you for considering my comments.