Subject: SR-NSCC-2021-010
From: Daniel Bezruchkin
Affiliation:

Feb. 13, 2022



Comment for SR-NSCC-2021-010:

This rule is unacceptable. Bad faith actors with repeated fines and offenses should not be given preferential treatment via more loopholes they can abuse. They have proven time and again these leniencies will be exploited at the cost of all other Wall Street players as well as the larger economy stability.

If there are losses as part of the parties bad risk management and overleverage, the parties that caused the situation and the parties that enabled it should brunt the majority of the losses. Protecting these parties from such mistakes will just lead to more bad practices.