Apr. 20, 2022
Dear SEC, These are my comments on SR-NSCC-2021-003 and SR-NSCC-2022-801 I grew up learning a saying in Sweden (I have been an American Citizen since 2012) which went as such, "As you Make your bed is how you will sleep in it." The meaning of this saying is that you will have to take the consequences of your actions. With this rule, you are not protecting the retail investors but the big hedge funds who make a living of naked shorting business and bankrupting them. It is time for them to receive the consequences of their actions. What they have been doing is illegal and you know it. They have also put businesses like Toys 'r Us, Sears, and others, out of business. The market makers such as Citadel are also big into this business and making good money in destroying businesses. It is time for these people to man up to their actions and take the consequences for what they have been doing. There are people who have fought back against the Wall Street corruption and you are a Government organization that reports to We the People! So let's take a look at the issues with this proposal. Page 6: Fire Sale Risk Mitigation In addition to creating capital efficiency opportunities for market participants, NSCC believes that broadening the scope of central clearing at NSCC to SFTs would also reduce the potential for market disruption from fire sales. In the case of securities lending transactions, the primary risk of fire sales relates to the reinvestment of cash collateral by institutional firms that are the lenders in securities lending transactions. Those institutional firms will typically reinvest the cash collateral they receive from the borrower into other securities. If the borrower of the securities thereafter defaults, the institutional firm lenders generally need to quickly liquidate the securities representing the reinvestment in order to raise cash to purchase the originally lent security. A substantial number of disconnected and competing liquidations by multiple lenders can create fire sale conditions for the securities being... So this is my understanding of this portion of the rule. "We are going to naked short. If we can't locate, instead of FTD we are going to create a temporary IOU and when the time comes, if we can't locate again we are going to create another IOU to replace the original IOU and keep getting away with our scam." If I was doing what this is granting the Short Hedge Funds (SHF) to do I would go to jail. I believe in Free Market and you are regulating the Free Market. Let the SHF take their consequences of their actions. Have you read the book "Anti Fragile" by Nassim Nicholas Taleb, Joe Ochman, et al. This book is great and a part of it is talking about heavily regulated processes are extremely fragile and processes that are much less regulated, like how the Free Market is supposed to be, are extremely anti fragile. Your continually meddling with things are very fragile and you are ruining our economy. Stop making rules that are protecting the ultra rich, and let the Free Market reign. Let business fail without your meddling rules, and let new businesses and people raise from the ashes. To be honest, you are not even a constitutional entity. Not to mention you are protecting another entity (The Fed) which is not an constitutional entity. Have you read the book "The Creature from Jekyll Island: A Second Look at the Federal Reserve" by G. Edward Griffin? If you don't want to get into the 500 page book you can always read the 25 page Tuttle Twin version. Needles to say. Just that one paragraph about Fire Sale page 6 should disqualify this proposal all together. Sincerely, Hans-Erik