Subject: SR-NSCC-2022-003
From: Seth C
Affiliation:

Apr. 20, 2022

 

Hello,
It seems anti-American to create rules and law that benefits a few wealthy individuals at the expense of the people.
The proposed rule is not just a can-kicker, it's a Market Maker's "infinite share loophole," an Overnight Reverse Repo, and a dark pool internalizer all-in-one!
The prime brokers, the hedge funds, and the market makers will be able to simply request an SFT 'loan' on a share that doesn't exist, anytime they want. 
In return, they're suggesting that the SFT be paid for by posting "cash collateral equal to the market price of that security." THIS IS JUST A MARKET ORDER BY A DIFFERENT NAME! It's a completely off-exchange, re-routed buy order from an NSCC-sponsored dark pool with an infinite supply! It doesn't matter if it's "overnight" or temporary. It's creating liquidity from shares that do not exist!
Further enabling a few individuals in the already wealthy upper class to not suffer the consequences of the gamble they made on the market does nothing to stop this same behavior in the future. You would be giving them the keys to the printing press.
I do not support this rule / bill/ proposal.
Seth Cope