Apr. 20, 2022
To whom it may concern: One of the most notable lines within a congressional hearing I have ever been able to witness describes, extremely well, my personal involvement into my own investment philosophy. "I am not an institutional investor, nor am I a hedge fund, I do not have clients, and I do not provide investment advice for fees or commissions." This was stated by Keith Gill during his testimony in the congressional hearing on February 18th 2021. Like the rest of his testimony, I have personally done my own research and taught myself the stock market and what it can provide. I have done my own research on many companies and have learned from my own failures of these markets and have gained and lost money from the same markets. I am your typical individual investor, also known as your retail investors. Just as Keith Gill also stated during his testimony, I support the right for retail investors to invest in what they want, when they want. I support the right of individuals to send a message based on how they invest. My own personal investments can not move markets nor stocks. The proposed rule, SR-NSCC-2022-003, effectively increases avoiding true market price, which also effectively removes the infinite risk that comes from naked shorting. This provides the exact players that can move markets, an easy out for their "obligations" and increases their risky business practices. The rules are proposed by the very entities that benefit from the passing. With every trade, there is a direct counterparty to those trades. The counterparty for these exact trades, are your retail investors. Retail does not fight in the same "fair" market that the institutional investors, market makers, or hedge funds play in. This is NOT the fair market that should be shown to the world. The market already lacks true transparency and accountability from these same large players. The Security Financial Transactions (SFTs) from this rule (SR-NSCC-2022-003) would provide a way to create an endless layer of Failures to Deliver (FTDs) in many securities and obscure real obligations of these same financial institutions against retail investors. I have personally learned from my own investments and am responsible enough for the amounts of my losses. How is it possible my counterparty, these financial institutions, are not able to be responsible for their losses as well? Instead, they propose more rules and regulations to remove their own obligations and failures in the markets that they personally have created. This same concept policy has been proposed TWICE before under different proposals because the same entities are likely caught under their own poor decisions and responsibilities. This rule should NOT pass Non-Retail investors already have multiple "reset" methods to clear out their obligations. What every party needs, is transparency, accountability, and proposals that benefit all parties involved. Individual retail investors may not be an educated and experienced party today, but will likely have a huge impact for investing tomorrow