Subject: SR-NSCC-2022-003
From: Roderic Broeker
Affiliation:

Apr. 20, 2022

 


Good day,

Though I am not an American citizen, I do invest in American companies trading on American markets. 
Over the past few years, what I have observed in the markets has made me lose all faith in them.
Non-institutional/individual investors are at the mercy of market makers and prime brokers. How they route orders effectively determines price action, and any semblance of true price discovery in a free market is long gone.

This new rule change being proposed, SR-NSCC-2022-003, seems to entrench this trend. 
To simplify: 
- Does the new rule work toward further transparency in the markets, or help to further obfuscate abuses?
- Does the proposed rule enable further abuse of dark pools or restrict their use?
- Does the proposed rule ensure that failures-to-deliver are limited or encouraged? 
- When short sellers are called to close their short positions, will it be that they have to do so on the lit market?

These questions point toward the concerns of individual investors. I have seen plenty of care and concern for institutions already.
Unless rules being proposed start to reflect these concerns, then regulating bodies can expect worldwide withdrawals of capital from American markets by individual investors, as individuals will seek decentralized financial markets to invest in.

True price discovery in a fair and free market. That’s what was promised to me in my youth and it has been taken from me by shadowy predators. 

Laws and rules, fundamentally from the time of Hammurabi, were made to protect the vulnerable against the strong and tyrannical. Ask yourselves who this new rule is designed to protect. Then ask yourselves what kind of world you are helping to build.

Roderic Broeker




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