Apr. 20, 2022
Greetings, The proposed rule change SR-NSCC-2022-003 seems to further insulate bad actors from the consequences of the riskiest and most reckless behavior within our markets today. The inherent risk of carrying massive overleveraged short positions with significant borrowing fees that have the potential for infinite loss while piling up massive amounts of FTD's should be deterrent enough for market participants beyond specific circumstances. Instead, thanks to all the unethical smoke and mirrors, intentional overcomplexity, multiple avenues for rehypothecation, obfuscation and non-disclosure; this trading strategy has become the de facto law of the land in modern equity markets. To approve this rule change is to make the statement that "privatized gains and subsidized losses" are a very real thing. It would illuminate a big flashing sign to the world that our markets are nowhere near "free and fair" and that price discovery will always be controlled by those with the power to pay "cost of doing business" fines and who can lobby to empower those who can enact lopsided rule changes such as SR-NSCC-2022-003. I've entered ignorant overleveraged positions before, and you know what I had to do? Lose money and learn a lesson. The market should be a zero sum game for EVERY participant, not just disadvantaged retail investors.