Subject: SR-NSCC-2022-003 Notice of Filing of Proposed Rule Change to Establish the Securities Financing Transaction Clearing Service and Make Other Changes
From: Morten Breiland
Affiliation:

Apr. 22, 2022

 


Hi, thank you for taking the time to value mine opinion on regards of this proposed ruling. 

After my third year investing in the US market, I have learned more and more about the US market structure. I am from Norway and used to set regulation that keeps good balance for big, smaller investors and institutions who does risky bets and being over leverage must obey the set regulation as anybody else. Being bail out from bigger institutions or banks is not an option in the Norwegian market, nor European market, as this proposed ruling offers.

This ruling at my perspective and meaning, is where some institutions/Hegde funds will not be held accountable for their risky bets and gets their "get out of jail card" by being rescued by bigger institutions (banks and so on), for FTD and naked-shorting (for example not being margin called). It clearly shows where bigger institutions are getting a backdoor exit route to avoid being held accountable for their overleverage and misbehaving by naked shorting a company. 

This proposed ruling does not benefit retail and are more beneficial for bigger institutions (who already is not playing by the rule, because there is no such thing as conflict of interest in the US market?) for not facing their economic risky bet(s) and avoid a potential squeeze scenario or disrupt in the market. I find it sensational how this rule is being proposed, where SEC is for the retail and not institutions(?). This ruling will not rescue retails for potential losing money due to squeeze or disrupt in the market, this will only give the Hegde fund a way out of a sticky situation, which they themselves ended up in.

I have realized how much the US market is beneficial for the institutions and not retail, how some Hegde fund/market makers are hovering the market to not playing by the rules, and not being held accountable for. This proposed ruling will put the US market in a different light for foreigner investor and strongly suggest to not enforce this proposed ruling. 
More I learn about the US market, and how the SEC should protect the retails. The structure in the US market and how the SEC is ignoring the retails voices shocks me. If this path continues, it will end bad for the US market, foreign investors, and national investors (retails) will pull out of the market at the end. Retails will no longer play your game, where the same team always win and changing the rules during a match. 

I hope you take my opinion into consideration and excuse my language = trash this proposed ruling. To prevent a market disrupt, there cannot be a backdoor exit route for the Hegde funds and other institution. If you place a bet, all parties are aware of the risk, and this must apply all parties. The rules cannot change in the middle of a match. 
By ignoring retail is voice, is dangerous for the US market. Please listen and do not destroy your own market by letting some Hegde fund and banks slip out the backdoor, because of their own mistakes.


All future events become history; how does SEC want be in this history book? As a party who ignored the retail and overlooked while the big Hegde funds robbed the little guy? Or the party that stood for a clean and justice market, for protecting the retail?

Sorry for my English and grammar. I hope SEC is understanding the essence and the importance of this letter. 


Best regards
Morten Breiland

Norway