Subject: SR-NSCC-2022-003 Comments
From: Gabriel Bruskoff
Affiliation:

Apr. 20, 2022

 



Are you kidding me with SR-NSCC-2022-003? 


You guys just keep making the markets more and more complicated, a larger and larger web of complexity and craziness, and for what reason? Definitely not retail, for whom this new rule does not benefit at all. So who or what is it for? Hedge funds to make even more money on the backs of retail, which would make you derelict of duty and evil? Or to starve off collapse? I certainly hope its not the latter, for adding complexity to starve off a system's collapse does not work. All it does is delay, which in turn results in the collapse being that much bigger than it otherwise would've been. So if this is what you are going for, you may not be evil but you definitely are incompetent, and also derelict of duty since you are making things worse. 


Make the markets simple. Buy a share, sell a share. Short a share, located said share and close it. Simple as that. If people can't play by those rules then don't let them play, don't continually alter/adjust/complicate the rules to accomodate bad actors. That will just result in collapse, and if you go this route, the more you do to prevent the collapse, the worse the collapse will be when it happens. 


SR-NSCC-2022-003 should not pass. If someone shorts a share, it is their responsibility to close said short. If someone shorts too many shares, it is still their responsibility to close them. It is not the system's responsibility to bail out entities who make bad investments, who take on too much risk, who try to cheat or otherwise manipulate the system, or whatever, and this is true even if that means said entity goes under. When shorting, especially when over-shorting, bankruptcy is a risk you take, so let whoever shorted too much face the consequences of their actions; if that means bankrupty for them, well that's how free markets work. 










Gabriel Bruskoff 
818.641.3580 
  

www.gabrielbruskoff.com 

Writer/Director: What We're Meant For 
Creator: Movies Under The Surface