April 20, 2022
To whom it may concern,
As a retail investor, the rule proposal SR-NSCC-2022-003 is frustrating, angering and saddening. The 'free' market is not only opaque but a proposal such as this adds to that issue. As a husband, father, and tax payer who swings a hammer for a living, my free time shouldn't have to be spent fighting for retail investor rights that are being eroded not only by finacial institutions but by those that govern them such as the SEC.
SR-NSCC-2022-003 would allow the problem of FTD's and Naked Shorting to not only grow, but thrive. The use of SFT's would give yet another tool to finacial institutions to safe-guard their own bad bets at the detriment of not only retail investors but American citizens. This rule would increase avoidance of market price discovery through onward lending. This proposal in it's current form would exponentially increase share lending without accountability for bad actors putting everyone else at risk, especially those most vulnerable, retail investors.
This rule would encourage NSCC members to take greater risk, saying that if you get caught you can get a cash loan to bail you out so you don't need to liquidate. This in my eyes creates an incentive for market participants to pass risk onto the broader market and ends with tax payers having to rescue any true market crisis. Plainly put, this rule strengthens an already to big to fail model currently employed.
This is a plea to not only strike this proposal down but consider future rule proposals from the perspective of retail investors, not institutions. It is very clear that laws and regulations have been put in place not for the betterment of markets and society, but for financial institutions.
My over use of 'not only' should point to the plethora of reasons this proposal is not only wrong but unethical. If the mission of the US SEC is truly to protect investors, maintain fair, orderly, and efficient markets and facilitate capital formation than this rule should not have made it to proposal form.
This rule does not protect investors. It protects institutions. It does not maintain fair, orderly markets. It tilts market fairness to institutions. It does not facilitate capital formation. It shrouds the formation in further corruption.
It is NO on SR-NSCC-2022-003 from me and I hope the SEC will come to the same conclusion.
Thank you for your time and consideration.
Tyler Matson