Subject: SR-NSCC-2022-003
From: kian jolley
Affiliation:

Apr. 20, 2022

 





To whom it may concern, 




NSCC has proposed a new rule that is absolutely disgusting. It caters to the big corporations that have had to resort to illegal naked short selling and FTD to stay alive. This proposed bill will allow them to get around these disgusting practices making FTD "normal and ok to do". 


I will explain the rule in a dumbed down version since apparently that is the only way to come across to the SEC. 


"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 like $1,420,696,969,420,741. 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." 


Market buy-ins should be the ONLY way any single entity, be it retail or Hedge Fund should be allowed to get shares, not through some made up SFT to help the big "too big to fail" players from stealing money from us like you have allowed them to do all these years. 


This rule screws over retail which the SEC has promised to protect. If this passes you have failed, you have already failed but this will be the last straw. If this passes this affects the whole market, this will destroy any remaining "free" aspect of our US markets. This is the first time I have emailed the SEC but at this point with how messed up the NSCC, the SEC, the DTCC, and all big Hedge Funds are, I will now email all the time to make sure the people that are working hard to screw over retail are given what they deserve. 



Kian