Subject: SR-NSCC-2021-801
From: N/A N/A
Affiliation:

Apr. 09, 2021

 



Good morning, 


Enacting this rule will be a step in bringing additional accountability to the practice of short selling and help with legitimacy concerns associated with an otherwise valuable function. Rapid trading and information exchange in the modern era has only heightened this need; in fact, the lack of more frequent updates is remarkable.  


Given the events of the year to date and this past year with widespread, opportunistic, and perhaps even abusive short selling of the market, faith in the US stock market has waned, particularly for smaller investors who have faced increased restrictions on trading when their positions have an advantage over institutions. The asymmetry has greatly enriched some large institutions, while siphoning money from small businesses and individuals unable to survive COVID restrictions.  


Despite now being a sizable and actively participating portion of the stock market, individual investors face multiple roadblocks to their success. An information asymmetry has been enabled and encouraged by infrequent updates and minimal fines for infractions. The borderline ridiculous blame placed on small investors for market volatility recently has been particularly infuriating to some investors who have lived through the events of 2008, let alone other major events like 1987. The liquidation of Archegos Capital has re-emphasized this point, with an opaquely structured fund taking on inordinate amounts of leveraged risk and causing multiple billions of dollars' worth of damages--all features unavailable to the average individual investor. 


In addition to enacting this rule, disciplinary actions should be sufficient to discourage the behavior, rather than simply being a fractional cost of doing business. 


The US stock market has become an increasingly unattractive investment for me personally and I suspect many others feel the same way. The SEC has an opportunity to correct this. 


Thank you for your time, 


Josh Cassedy