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