Apr. 09, 2021
To whom it may concern, I am in full support of this regulation and the transparency and stability it will afford the members participating in the DTCC. While a considerable amount needs to be changed going forward in order to bring true freedom and accountability to the U.S. markets, I believe this regulation is a significant step toward a positive change that benefits both the retail sector and those entities who wish to reap the rewards of a robust and healthy economic environment within a reasonable and secure rule of law. There needs to be greater transparency and accurate, up-to-date information, updated daily regarding the positions taken by Institutions, Hedge Funds, etc. Currently, there is broad speculation about how many companies that have been shorted, how many synthetic shares have been sold, the murky transactions in Dark Pools, Failure To Deliver information, etc. This leaves the investors, and productive companies at an incredible disadvantage and extremely vulnerable to the market manipulation of these institutions, (for example 1000 US companies per year are bankrupted for the tax free gains on short positions as a result). Protection of the market against these infractions is paramount, and resolution is sorely needed which will therefor level the playing field. Please pass and ratify rule NSCC-2021-801 with unanimous consent. I request immediate implementation of this rule to accurately identify the legitimate numbers regarding stocks across the market--specifically the number of synthetic shares that have been sold, the real stats related to naked shorting and the FTD numbers. Currently it seems that there is enormous market manipulation and deceitful and misleading conveyance of these numbers. Imposition of the harshest penalties for all manipulation or obfuscation of reported data, is desperately required. Current penalties are ineffectual, as the fines are insignificant to these multi-billion/ multi-trillion-dollar institutions and treated as a fraction of a percentage “cost of doing business” in fact, these fines are such an ineffective deterrent that institutions have flagrantly violated rules with full knowledge and intention; knowing that it will cost them a pittance in fines compared with the money they will make by violating the rules. The SEC should immediately approve of and enable NSCC-2021-801, and immediately implement this rule to bring begin restoring confidence in the US markets for both the US domestic investor, and the international investor who may be averse to future investments within US markets if this not resolved. Thank you for your time