Subject: SR-NSCC-2022-003
From: B. Duane Jacobs
Affiliation:

Apr. 20, 2022

 


Implementing this rule would be counter to your stated mandates of "protecting investors" and "maintaining fair, orderly, and efficient markets" and would further tarnish your reputation as an independent arbiter of said markets. Creating unnecessary and immoral securities derivatives most likely allow you to fulfill your third mandate of "facilitating capital formation" but does not serve your greater mission, does not protect Main Street investors, and does not aid in bringing security to the financial futures of regular investors. 


The time for creating obfustication and telling the common person it is in their own best interest is over. All of the regulatory bodies that have been failing at their missions and failing the American people no longer get to continue to proceed with their purposefully obscure dealings in the dark. You can not protect those that you purposely misinform. 


Do not implement this rule and do not attempt to implement another rule similar to it. If large institutional investors can not operate within the rules, they must deal with the outcome of their actions the same as any other person or entity. The market can be a tough place at times and you don't always win; it is beyond time for those that have been rewriting the rules to avoid losing to face the consequences of their misguided actions. 


Anyone worth their salt at the SEC that is earnestly attempting to uphold their mandates would be against adding another layer of inefficiency and purposeful obfustication. Please add my comment to the deluge you must be receiving as this rule is contradictory to a fair and efficient market. 


Thank you for your time.