Subject: SR-NSCC-2022-003

Apr. 19, 2022



Hi,

I’m writing in regard to proposed rule: SR-NSCC-2022-003.

I’m emailing this same letter to my Federal Senators and Congresswoman for visibility on this proposed rule change.

The proposal can be found here: https://www.sec.gov/rules/sro/nscc/2022/34-94694.pdf

I would like to first ask my Federal Representatives, Sen. Grassley, Sen. Earnst, and Representative Miller-Meeks to consider who is watching the SEC? The Auditors, Commisioner Lee and Crenshaw. Who is watching the Auditors?

In the end I’m going to ask for your support in stopping bad actors on Wallstreet. We need market reform, and we need it now before the average voter with a pension, retirement account, or investments gets poorer and Wallstreet fleeces America for everything it has.

This SEC proposal is not in the interest of RETAIL. This does NOT lead to Transparency or hold those who have put this country at risk accountable.

I ask the SEC and my Representatives to take action and to prevent this proposed rule from being enacted. This rule does NOT instill trust in the market for Retail investors, at all. Further, the “Watchers of the Watchers(SEC)”, namely the Auditors are also promoting distrust in our ‘free and fair market’. From the Auditor’s website:

“Auditors play a crucial role in promoting public trust in our markets by providing assurances about the reliability of financial disclosures. This role has been described as a “public watchdog” function “

The proposed rule does nothing remotely close to instilling public trust and needs to be struck down immediately and permanently.

The SFT service is completely voluntary and NSCC members are being essentially enticed to participate in it. The SFT novates all old obligations into new ones so whatever rules and regulations that pertain to whatever security and/or participant are voided. Footnote #20 basically admits to this when it says that a direct service would "not likely be compatible with regulatory requirements", implying that this indirect transaction clearing service "avoids" those requirements.

It's a heinous rule for retail. How is this legal?!

On page 2, “Fire Sale Risk Mitigation”. It looks like a rule to lessen the chances of Retail being able force short sellers to cover their shares in the event that they lose their bet. This is gaming the system!

This proposed rule benefits one group of investors, those who run Wallstreet. Retail investors, people with pensions, retirement accounts, and any exposure to this market are at risk of getting fleeced by Wall Street
with this rule proposal.

People who have placed trust in a fare, free market, can essentially be ripped off by more knowledgeable investors (Wallstreet) because they/we can not possibly manage to keep up with the increasing complexity that is continuously engineered into the market to benefit Wallstreet. It negates any opportunity for a Retail investor to get a FAIR SHAKE in a “free market”.

If the SEC doesn’t protect people from Wallstreet predators then why should anyone at all invest in this market? They shouldn’t.

The SEC, in fact, seems to be very deliberately and diligently creating a lopsided playing field favoring Wallstreet with rules like this!

How dare the SEC claim this is a free and fair market.

I ask the SEC to immediately stop the adoption of this rule.

I ask my Representatives to protect your voters from this blatant corruption and attempt to unfairly game the system and take from those who can’t protect ourselves.

Thank you for your time and Consideration.

Best regards,
Mark Kane