Subject: SR-NSCC-2022-003: WebForm Comments from Phil Graham
From: Phil Graham
Affiliation: Retail Investor

May. 31, 2022

May 31, 2022

This rule change should not be allowed. Continuing to create these CNS pools ( what I like to call lifelines) for the bad actors, who made bad bets and are ridiculously over leveraged will only continue them to keep going.  I understand margin calls and fire sales arent wanted, but these institutions need to have consequences for their lack of risk management. Rather than create another CNS that allows them to basically do the same thing in this new CNS that they did in market that brought them here.  This in no way helps the majority of retail investors, as it would only affect those investors vested with the bad actors.  Investigate why these institutions are being margin called and causing any market disruption instead giving them yet another loophole to exploit and do more damage.