Subject: SR-NSCC-2022-003
From: Dan Heise
Affiliation:

Apr. 20, 2022

 


I am writing as a retail investor to express concern over this rule and its implications. As I understand it, this allows an essential like-exchange agnostic to the success of a company wherein $100 (or $100MM) of an abusively shorted stock can be exchanged for $100 (or $100MM) of any other stock, thereby eliminating the risk of short selling. When any person or entity short sells a stock, they knowingly take on that risk and should have no other way out of that gamble other than to purchase that stock back to satisfy the debt that comes with a short sale. 


Imagine, if you will, you bet against someone in poker with a bluff. The person across from you goes all in, and they are holding a flush. You bluffed with a two-pair, but thanks to a rule like this, you can swap your two-pair for a four-of-a-kind. That is unethical and breaks the rules of poker. You allow this bluff to turn around into a win at the expense of the player with the better hand. If you allow "rules for me, not for thee" as what's suggested here, you blatantly hand all abilities to legally manipulate the market (at will) to those who have shown to repeatedly abuse any and all advantages they are given over retail and institutional investors alike. 


Please keep in mind, you are also dealing with entities who will gamble away the pensions and retirement accounts of hard-working Americans. If they are callously betting with mind-boggling levels of leverage, they must be held accountable when their bluff is called and they must stop their abuse of rules that have, for far too long, given an unfair advantage. 


Sincerely, 


Dan Heise 
812-606-2980 

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Dan Heise 
Multi-Line Agent 
Tactical Insurance Advisors 
P: 812-414-5885 
E:   
www.mytacticaladvisor.com