April 19, 2022
I'm a small business owner and retail investor, reading through the proposed rule change, and I see it as horrifying that this much effort is going into additional resources to allow hedge funds more runway for hiding their Failure to Delivers and manipulation techniques.
The proposed rule change is specifically written as a benefit to hedge funds, as mentioned on page (3) of the 188 page document, \"transferring those securities temporarily to a borrower (typical a hedge fund)\". This sounds like a way to enable hedge funds to continue their practices of phantom shares and fails to deliver, using their High Frequency Algorithms against retail investors who are prevented from such activities via various rules about \"day trading\" \"swing trading\" and delayed market data. The markets are already so incredible skewed against retail investors actually owning the securities they paid for that it seems criminal to write even MORE special rules to enable Hedge Funds to borrow things via more complex transaction methodologies not available to others in the \"free market\" that the NSCC / SEC/ DTCC is supposed to protect and encourage.
So, SEC folks: How about some rules that benefit retail investors, rather than making up more fancy ways for Hedge Funds to cover their delinquency and shade their dark pool activities? You already allow a handful of hedge funds to front-run through Payment for Order Flow the vast majority of retail trades, justified by hand-waiving over liquidity, while simultaneously allowing \"fills\" of those orders via phantom-share plate-spinning and a chronically broken short interest reporting platform.
The proposed rule change SR-NSCC-2022-003 seems to enable _another_ way to spin FTD plates without ever actually delivering the assets to the owners who bought them, by adding another layer of ridiculous special treatment for the handful of Giant People who essentially have been succeeding in turning the US Free Market system into an oligarchy ran by a few giant \"hedge funds\" who also happen to be market makers, dark pool traders, brokers, and high frequency traders. This ruling appears to be a further direct attack on the rights of Retail Investors and other long term value investors who expect the securities they pay for to be owned by them, and not be made readily available for shorting, can-kicking, SFT Cash Deposit Rehypothecation, or otherwise.