Finding a Better Value Proposition for the SEC's Sec Lending Disclosure Rule
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 on specific ideas they want explored. The Commission has seemingly outsourced the economic analysis of its suggested alternatives to industry commenters. Also, by doing so, the Commission has hinted it is interested in hearing about well-supported alternatives, and may even be inviting counter-proposals.