Apr. 20, 2022
To whom it may concern, As a retail investor and proponent of fair and transparent markets, I am vehemently against this proposed rule change by the NSCC. Our markets are already severely lacking in transparency and accountability and are full of extremely complex rules, mechanisms, and products that have largely been developed and implemented by large institutions, hedge funds, and market makers to serve their own bottom line. I have read the entire proposal and while I am not a financial professional or lawyer, it is pretty clear that this rule is largely attempting to further suppress price discovery via onward lending. Removing risk and capital requirements for risky and in some cases illegal business practices (such as naked shorting) so that many of the 'members' do not have to answer for or deal with the consequences of their risky plays. This is all proposed under the guise of 'liquidity' and 'risk aversion' - which are both laughable in this situation. The upside here is for hedge funds and large market makers to allow further abusive shorting and naked shorting, while further enabling their ability to suppress fail to delivers (FTDs) and limiting their exposure in the event of bad decisions and investments, the opposite is true for businesses and investors that choose to participate in the market. These investment banks, hedge funds, and market makers can not be allowed off the hook for poor decision making, if that means they get liquidated and some of them fail, so be it. Nobody is 'too big to fail', period. If they fail and it becomes a major issue, then we need to identify WHY, fix the situation, and ensure rules are put in place (AND enforced) to ensure it does not happen again. Furthermore, this is at least the third time that similar rule changes have been proposed, being rejected or withdrawn previously. I would like to see formal and public comment on these proposed changes and statements or policy made specifically against them so this is not a perpetual cycle of trying to get these pushed in under the radar of individual investors. I strongly feel that many investors' faith in the US financial markets is dangerously close to being lost, rules like this will only further erode that faith. Along those lines I would like to see the SEC addressing some of these topics publically with rule changes and true enforcement to combat things such as dark pools, FTD's, naked shorting, the lack of true price discovery, and so on. I respect the difficult situation the SEC is in and I appreciate you taking the time to consider my and many other individual investors' comments. Best Regards Matt Klukas