Apr. 20, 2022
Hello there, I'm taking some time out of my day to comment on the proposal to allow a shifting of obligation of short sellers to settle with the NSCC. Having rules enforced stringently is important to maintain trust in our financial institutions and regulators. If short selling is conducted fairly, at some point that short seller of equities needs to repurchase shares on the market. It's a well known fact that our market is producing FTDs (failures to deliver) at an alarming rate. And there is some evidence that ETFs make it possible to provide more liquidity for our markets, and at the same time could be contributing to this problem of price suppression on certain stocks. If the rules change on this issue, then we will be allowing potential bad actors to flip a coin on their bets. Heads, I win. Tails, I still don't lose. Please continue to enforce the rules and reject this proposal. Sincerely, Michael Smith