Apr. 20, 2022
I am writing as a continental US retail investor, very concerned about the implications of the rule you proposed. After going through the file twice, it is very clear to me that the rule in fact acts against the interest of retail investors, whom SEC is supposed to protect. It does that by increasing possibility for avoidance of true market price discovery through continuous lending. It also significantly lessens the infinite risk of naked shorting. That practice, as I am sure you are aware, is by nature very risky and for a good reason. Without that risk, the institutional investors are free to essentially gamble with taxpayers and retail investors money, posing systemic risk to the integrity of US stock market (you would have the same credibility as London Metal Exchange). What we need is more transparency in how stock market works to level the playing field between retail and institutions, especially considering the widening wealth gap and soaring inflation, among other problems our society faces. The proposed rule acts in the opposite direction. I consider that transparency essential for a fair and sound economy, as well as for the democracy. Having said all that, I sincerely hope that whoever this concerns, will re-evaluate their position and withdraw that ruling completely.