Apr. 20, 2022
Good Afternoon, I am a retail investor, and I am writing to you in protest and opposition of the proposed rule change SR-NSCC-2022-003. Frankly, this proposed rule change seems to be intentionally hostile to the retail investor The proposed change seems to only exacerbate the problem of Failures to Deliver (FTDs) by allowing Securities Financing Transactions (SFTs) to be used in place of real assets to satisfy an FTD. This change seems to me to be a death blow to the "free" market in the United States, by allowing overleveraged financial institutions, who in all likelihood maintain short positions, to skirt their delivery obligations. This process would be nothing short of exploitative of American retail investors. As a retail investor, if I were to purchase a security that was never delivered to me, how does an SFT make me whole? Am I not still without the asset that I purchased? I would love to hear an explanation from the SEC on how this does not constitute theft and fraud. How does it not constitute market manipulation? Any retail investor who makes the decision to enter American markets finds themselves swept up in a sea of complexity that increasingly seems to favor financial institutions over the retail investor. All 188 pages of this proposed rule change is just another example of this needless complexity that seems designed to disadvantage the retail investor. I dream of the day when I will be able to invest my money into markets that are free and fair for all involved. However, with this proposed rule change, it seems that free and fair markets will remain just that, a dream. With that said, I implore you to strike down the proposed rule change. Our markets will not be free and fair with this rule in place. Sincerely yours in disappointment, with the hope that you will do better, Thomas Ruhl Retail Investor