Subject: SR-NSCC-2022-003
From: Jason Hardon
Affiliation:

Apr. 20, 2022

 

This rule is the most egregious, disgusting, backstabbing, festering pile of corruption that the US stock market has ever seen. I do not support this proposal. This rule proposes using a vehicle, they call an SFT (Securities Financial Transaction ... sigh), as a placeholder for any securities transaction. As I understand it, these SFTs are fungible like a dollar bill. So, if you have 100 worth of SFT that you SHORTED, and want to Fail to Deliver rather than buy-in at market value, you can resolve it by utilizing another SFT worth the same amount set for the same delivery date. The cost one would pay for this "feature" would be based on the difference in closing price from one day to the next. This cost would be much cheaper than a market buy-in, especially when the floor for a security is a high number. Seems like a cheap way to can-kick a scary-ass FTD problem (idiosyncratic risk anyone?), rather than buy-in at current market value. I.e. seems crafted to protect the practice of abusive short-selling, when it doesn't work out for the SHF lease reject it. Thanks. the complexity of rules that govern our fair market, are not created by Retail, rather by Wall Street, big banks, and Hedge funds, and they use the complexity to their advantage. This rule is just another example of leveraging complexity to fleece over retail by keeping them ignorant. 

Sincerely 
Jason Hardon 

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