Activities & Engagements

CSFME is an independent, nonprofit organization with a mission to help improve transparency, reduce risks, support research, and promote sound regulation of financial markets. We conduct data-driven analyses, provide investor education and outreach, and support regulatory reviews in otherwise opaque markets. 

The Center works with investors, service providers, academics, and government regulators. Our research is focused on the securities finance industry which supports all investment markets. CSFME’s founder created the first securities loan pricing and benchmarking systems and pioneered many of the securities lending metrics used today. 

Since the 2008 financial crisis, CSFME has closely monitored efforts to bring securities lending out of the stigma of “shadow banking.” Recommendations have been made by global standard-setting bodies, including the Financial Stability Board and Basel Committee on Banking Supervision, as well as government data-gathering agencies, such as the U.S. Office of Financial Research. Regulators have responded with new disclosure regulations, most notably the Securities Finance Transaction Regulation (“SFTR”)1 of the European Securities Markets Authority. 

The Center has provided extensive feedback on the various securities lending regulatory frameworks proposed as well as substantive comments on details of models and pilots for data collection.2 We have provided written commentary and met with the U.S. Securities and Exchange Commission’s (SEC) staff to provide input on work on implementing aspects of Section 984(b) of the Dodd-Frank Act,3 including an August 6, 2021 letter to the SEC Chairman Gensler wherein we advised the Commission of our research plans.4 Lately, we have also submitted comment letters on the SEC’s proposal for securities lending disclosure.5

 

Milestones

 

2022 – Commented to SEC on Proposed Rule for Reporting of Securities Loans6

2022 – Meeting with SEC staff on Proposed Rule for Reporting of Securities Loans7

2022 – Conferred with RMA staff and members at Annual Meeting in Key Biscayne, FL

2021 – Presented to Beneficial Owners at IMN Securities Finance Conference 

2021 – Commented to SEC on Proposed Rule for Reporting of Securities Loans8

2021 – Podcast for RMA on Use of Database Models in Financial Markets9

2021 – Inquiry to ESMA on SFTR Reporting by Prime Brokers10

2020 – Recommendations to ESMA on Withholding Tax Abuse in Securities Finance11

2017 – Confidential Opinion on Proxy Voting, Securities and Exchange Commission

2017 – “Surprise! Market Theories Fail in Real-World Tests,” RMA Podcast12

2018 – Confidential Response Letter to the Office of Financial Research Pilot Survey

2016 – RMA Journal Article on Regulatory Reform”13

2016 – Comment Letter to Basel Committee on Step in Risk14

2016 – Regulatory Outreach for Student Education, Fordham University, BIS Consultation on Step-in Risk15

2015 -- Confidential Letter to The New York Stock Exchange on Lender Directed Voting16

2015 -- Comment Letter to the FSB on Global Securities Financing Data Collection and Aggregation17

2015 -- Comment Letters from Fordham University Students on Global Securities Financing Data Collection and Aggregation18

2015 -- Regulatory Outreach for Student Education, Fordham University, FSB Global Data Collection Consultation19

2014 -- Regulatory Outreach for Student Education, Fordham University, FSB IOSCO Non-bank Global SIFIs Consultation 201420

2013 -- Regulatory Outreach for Student Education, Federal Reserve, Treasury, SEC and OMB21 

2013 -- Meeting with CIO for NYC Pension Funds on Lender Directed Voting

2013 -- Borrowed proxy abuse study results presented at the 2012 IMN Beneficial Owners' Securities Lending Conference

2013 Presented the case for Lender Directed Voting to SEC Commissioner Dan Gallagher, 

2013 -- Meeting with staff of Senator Rob Portman and Congressman Steve Stivers of Ohio on Lender Directed Voting

2011 -- Published “An Interview with the Chairman of the Swiss Private Bankers Association,” ABA Banking Journal22

2011 -- Florida SBA Endorses LDV to the Securities and Exchange Commission23

2011 -- Met with the SEC Staff on Section 984(b) of the Dodd‐Frank Act24

2011 -- Testimony to the United States Senate Special Committee on Aging25

2010 -- Published Report on Borrowed Proxy Abuse26

2010 -- Comment Letter on the SEC’s Concept Release on the U.S. Proxy System27

2009 -- Comment Letter on SEC Securities Lending Roundtable28

2009 -- Testimony at the Securities Lending and Short Sale Roundtable29

2009 -- RMA Journal Article on Counterparty Risk Management30

2009 -- RMA Journal Article on Lessons from the Marke Crisis31 

2008 -- Interview with the SEC Chairman for the ABA Banking Journal32

2007 -- Presented Short Sale Study at to the World Bank and IMF33


 


1 Regulation (EU) 2015/2365 of the European Parliament and of the Council of 25 November 2015 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R2365&from=EN

2 https://www.fsb.org/wp-content/uploads/CSFME-on-1411DEG.pdf 

3 https://www.sec.gov/comments/df-title-ix/lending-borrowing/lendingborrowing-22.pdf. See also, https://www.sec.gov/comments/df-title-ix/lending-borrowing/lendingborrowing-16.pdf

4 Blount, Edmon W. Letter to Chairman Gary Gensler, "Re: Section 984(b) of the Dodd-Frank Act, Loan or Borrowing of Securities," August 6, 2021 (unpublished). 

6 Ed Blount, Comment letter to the SEC on Proposed Rule: Reporting of Securities Loans [Release No. 34-93613; File No. S7-18-21], November 1, 2022 https://www.sec.gov/comments/s7-18-21/s71821-20150128-316327.pdf; Ed Blount, Comment letter to the SEC on Proposed Rule: Reporting of Securities Loans [Release No. 34-93613; File No. S7-18-21], April 26, 2022; https://www.sec.gov/comments/s7-18-21/s71821-20146484-311684.pdf; David Schwartz, Comment letter to the SEC on Proposed Rule: Reporting of Securities Loans [Release No. 34-93613; File No. S7-18-21], March 17, 2022 https://www.sec.gov/comments/s7-18-21/s71821-20119858-272649.pdf; David Schwartz, Comment letter to the SEC on Proposed Rule: Reporting of Securities Loans [Release No. 34-93613; File No. S7-18-21], January 7, 2022 https://www.sec.gov/comments/s7-18-21/s71821-20111702-265034.pdf 

7 CSFME meeting with the SEC staff on Proposed Rule: Reporting of Securities Loans [Release No. 34-93613; File No. S7-18-21], April 26, 2022 https://www.sec.gov/comments/s7-18-21/s71821-20126846-287566.pdf 

8 Ed Blount, Comment letter to the SEC on Proposed Rule: Reporting of Securities Loans [Release No. 34-93613; File No. S7-18-21], December 15, 2021 https://www.sec.gov/comments/s7-18-21/s71821-20109658-264014.pdf

9 Ed Blount, “The Impact of Data-Based Models on Financial Markets,” RMA Podcast, June 7, 2021 https://www.rmahq.org/the-impact-of-data-based-models-on-financial-markets/

10 CSFME Confidential Memorandum to ESMA, Hedge funds and SFTR Reporting, February 28, 2021

11 CSFME Confidential Letter to ESMA, Withholding Tax Reclaim Schemes, November 6, 2020

12 “Surprise! Market Theories Fail in Real-World Tests,” RMA Podcast https://www.rmahq.org/surprise-market-theories-fail-in-real-world-tests/ 

13 “Unanticipated Adverse Consequences of Bank Regulatory Reform,” RMA Journal, September 2016.

14 CSFME Comment Letter, Basel Committee on Banking Supervision, Identification and Measurement of Step-in Risk, March 17, 2016  https://www.bis.org/bcbs/publ/comments/d349/cftsofme.pdf 

15 https://csfme.org/Outreach/ROSE/2016_ROSE_Data 

16 Stabilizing Corporate Governance and Stock Loan Operations Through Lender-Directed Voing. CSFME letter to the New York Stock Exchange detailing the benefits and legal considerations of Lender-Directed Voting, December 9, 2015.

17 CSFME Comment Letter, FSB, Standards and Processes for Global Securities Financing Data Collection and Aggregation, 2015, Feb. 12, 2015. https://www.fsb.org/wp-content/uploads/CSFME-on-1411DEG.pdf

18 FSB, Standards and Processes for Global Securities Financing Data Collection and Aggregation, 2015 https://www.fsb.org/wp-content/uploads/Fordham-Univ-students-on-1411DEG.pdf

19 https://csfme.org/Outreach/ROSE/2015_ROSE_Data 

20  https://csfme.org/Outreach/ROSE/2014_ROSE_Summary.aspx

21 https://csfme.org/Outreach/ROSE/2013_ROSE_Summary

22 Ed Blount, “An Interview with the Chairman of the Swiss Private Bankers Association,” ABA Banking Journal, November 2011

23 State Board of Administration of Florida, Rulemaking for Dodd-Frank Act Section 984, Loan or Borrowing of Securities/Securities Lending Activities, July 19, 2011 https://www.sec.gov/comments/df-title-ix/lending-borrowing/lendingborrowing-24.pdf 

24 CSFME Meeting with the SEC Staff on Loan or Borrowing of Securities: Title IX Section 984(b) of the Dodd‐Frank Wall Street Reform and Consumer Protection Act, March 30, 2011 https://www.sec.gov/comments/df-title-ix/lending-borrowing/lendingborrowing-16.pdf 

25 Ed Blount, “Risks and Responsibilities in Securities Lending,” Testimony to the United States Senate Special Committee on Aging, March 16, 2011 https://www.aging.senate.gov/imo/media/doc/hr232eb.pdf 

26 Borrowed Proxy Abuse: Real or Not? CSFME and RMA, October 20, 2010 https://www.sec.gov/comments/s7-14-10/s71410-174.pdf 

27 CSFME Comments on Securities and Exchange Commission’s Concept Release on the U.S. Proxy System, October 20, 2010  https://www.sec.gov/comments/s7-14-10/s71410-202.pdf

28 CSFME Comment Letter on SEC Securities Lending Roundtable, September 29, 2009  https://www.sec.gov/comments/4-590/4590-93.pdf 

29 Statement of Ed Blount for Securities Lending and Short Sale Roundtable, September 29,30, 2009 https://www.sec.gov/comments/4-590/4590-57.pdf 

30 Ed Blount, “Liability Dynamics, A New Analytical Framework for Counterparty Risk Management,” RMA Journal, March 2009

31 Ed Blount, “Lessons from the Market Crisis – What Can Be Done in the Future?” RMA Journal December 2008 - January 2009

32 Ed Blount, “Keep Functional Regulation: An Interview with the SEC Chairman,” ABA Banking Journal, October 1, 2008

33 Ed Blount, The Impact of Short Sales and Securities Lending on Capital Market Portfolios - 1990 through 2006, the World Bank – International Monetary Fund Conference to be hosted by the State University, Higher School of Economics, Moscow, Russia in April 2007.