Commentary

Wednesday, December 15, 2021

Beneficial Owners: "Most at risk, yet least served" by Disclosures

Comments to SEC on Proposed 10c-1 Reporting by Securities Lenders

Author: Ed Blount
CSFME comments on proposed Rule 10c-1, as submitted 15 December 2021 to the Securities and Exchange Commission: "With regard to the above-cited 10c-1 disclosure system, my colleagues and I consider inclusion in the rule proposal of an optional section on alternatives to be a genuine invitation to propose reasonable changes. We assume that the Commission must already realize that the mandated disclosure system, as currently proposed, will likely not achieve its goals.
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Monday, December 13, 2021

“Wisely and Slow; They Stumble that Run Fast.”

Finding a Better Value Proposition for the SEC's Sec Lending Disclosure Rule

Author: David Schwartz J.D. CPA
The SEC has proposed a radical and potentially very costly reporting regime for securities finance transactions to increase transparency "to brokers, dealers, and investors."  While there is no requirement for the Commission to discuss or examine the economic effects of regulatory alternatives, in this case, they have included some alternatives it could consider to the reporting structure they propose, presumably to focus potential commenters...
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Tags: securities lending, Capital Requirements, Counterparty

Monday, December 6, 2021

Selling Transparency: A Bean Counter's Blog

NEW DATA MODEL FOR SECURITIES FINANCE

Author: Ed Blount
A new disclosure data model has just been proposed by the SEC for U.S. securities lenders. Adoption of the model, called 10c-1 after the revised regulation, would be “one of the most drastic adjustments in the history of the securities lending industry,” writes Sidley Austin, a leading Wall Street law firm and advisor to broker-dealers. Previously, we have explained the proposal and intended benefits. Now we begin to analyze the proposed 10c-1 disclosure system’s value...
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Categories: All, Commentary, Formal Regulatory Remedies, Procedural Changes, Cross-Post

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Tuesday, November 30, 2021

Who Bears the Cost of the SEC's Securities Lending Disclosure Proposal?

The Winners and Losers in Mandatory Transparency

Author: David Schwartz J.D. CPA
The Securities and Exchange Commission (SEC) recently proposed a new reporting regime to increase transparency and efficiency in the securities-lending market. The proposal is a sweeping change and a somewhat novel approach to bringing securities lending out of the dark. While the merits of the proposal's approach will no doubt be thoroughly scrutinized and debated, so should its cost and who will bear that cost. While the potential benefits would seem to flow to all...
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Tags: securities lending

Sunday, November 28, 2021

U.S. Stock Loan "Ticker": A Gift to Beneficial Owners?

SEC's New Disclosure Regime to Fix "Information Assymetry"

Author: Ed Blount

Make no mistake. The new 10c-1 disclosure proposal by the SEC is an Investor Protection Rule on steroids. It is also a profound escalation of regulatory support for Investor Self-Protection. Nothing less than a near real-time stock loan ticker will result, if enacted, that is intended to reveal U.S. loan rates and liquidity to the investing public for the first time in history.

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Journal Commentaries

 

Keep Regulation Functional (October 2008)

CSFME’s Executive Director Ed Blount interviews SEC Chairman Chris Cox.
American Banking Association Banking Journal
https://www.questia.com/library/journal/1G1-187494664/keep-functional-regulation-how-financial-regulation

 

The Bear Market Posse, or Counterparty Risk Management during the Recent Turmoil (Sept.  2008)

by Ed Blount
The RMA Journal, v91n1, 28-32, 5 pages Sep 2008.

 

Searching for New Paradigms at BIS (July 2008)

by Ed Blount
Unexpected deficiencies in bank capital after recent market turmoil has regulators rethinking aspects of Basel II and “value at risk.”  
American Banking Association Banking Journal  
https://www.questia.com/library/journal/1G1-181991450/searching-for-new-paradigms-at-bis-market-turmoil

 

Will Basel II Affect The Competitive Landscape? (September 2003)

By Ed Blount
Newly elected Basel Committee Chairman Caruana, Governor of the Bank of Spain, gives his views on the revised Basel capital accord, relative to its potential effects on competition and risk management in banking markets.
American Banking Association Banking Journal
https://www.questia.com/read/1G1-108008773/will-basel-ii-affect-the-competitive-landscape-the​