MFA submitted a supplemental comment letter to the U.S. Securities and Exchange Commission (SEC) in response to the proposed rule on securities lending. The letter argues that:
- The Commission correctly acknowledged the costs and harm of revealing confidential short position information on a disaggregated and close to real-time basis in its proposed short position disclosure rule.
- The Commission’s proposal to reveal confidential securities lending transaction information on a loan-by-loan and close to real-time basis will result in significant costs and harm to the market and market participants.
- The Commission should revise the proposed loan disclosure rule to mitigate the significant costs and harm that were recognized in the proposed short position disclosure rule and would result from revealing confidential lending information on a loan-by-loan, fifteen-minute basis.
