April 20, 2022
I commented something similar for SR-NSCC-2022-801, the advance notice version of this proposal. I strongly oppose the implementation of proposed rule change SR-NSCC-2022-003. The proposed changes will add yet another layer of complexity and market functions that are accessible only to large banks and investment firms on Wall Street, making a system that is already too complicated, exclusive, and opaque even more so. The markets need to be simplified and made more transparent. Participants need to be forced to compete on a level playing field, and that means with the same tools, access and data as retail investors. These rule changes would further exacerbate the already vast unfair advantage that institutions have over retail and allow them to mitigate the risks involved with their reckless investments. Risk versus reward is a core concept with investing and if one wants to make a risky bet on the market they should be made to pay up when that ends unfavorably, not just shunt the liability into some new esoteric financial instrument that can be used to kick the can down the road forever. Participants should be made to play by the rules, and pay by the rules, not change the regulations to get themselves out of a bind. The SEC should reject this rule change the same way SR-NSCC-2021-010 the \"advance notice\" version SR-NSCC-2021-803 were rejected. Thank you.