Apr. 21, 2022
As a retail investor with a modest portfolio, I strongly oppose the proposed rule SR-NSCC-2022-003 as it is not in the best interest of fair and free markets. This rule provides benefits to institutional traders at the detriment of retail, and those without access to the same benefits of market makers. This rule closely resembles previous proposed rules which failed to pass for similar reasons and this appears to be nothing more than yet another attempt to pass rules that would seek to diminish the consequences of bad actors who already have significantly more resources, more data, and greater leverage in influencing market mechanics. The NSCC should not provide opportunities for any class of investor to avoid the consequences of their own actions, regardless of whether or not those actions create "idiosyncratic risk". This rule would allow a preferred class of investor to push boundaries and in many cases take even greater risks that destabilize markets and erode the trust in the American financial system, by providing an alternative to facing more significant consequences of such destructive activities as illegal naked short selling, PFOF and FTDs. While I acknowledge the immense challenge facing the SEC in monitoring market participants and seeking to improve market structure where needed, I am strongly opposed to SR-NSCC-2022-003 and ask that the SEC dismiss this rule proposal. Retail Investor & father of children watching whether the US financial markets are fair and equitable.