April 20, 2022
Considering there's currently a global scandal of a specific stock symbol ($GME) getting shorted with, on a conservative average of, 60% of its daily trading volume, for at least the past 15 months (putting the start date at 20 Jan 2021) -- a situation which is simply mathematically impossible considering that, in the past 15 months the trading volume has surpassed the available float of said stock ($GME) at least (again, conservatively) 37 times over (3,00,000,000 traded since 01 Jan 2021 vs 80,000,000 conservative float) when there's only, on average, 40% of the daily trading volume to buy back those shorted shares, with no single outlier day where the short percentage is virtually non-existent due to shorters buying shares to fulfill their delivery obligation of using borrowed shares to short with -- it would seem this rule should not only be rejected outright, but should cause the rule submitter's integrity to be formally questioned and vetted, along with financials verifiably checked, before the public's time is wasted reading any more proposals they may produce. It is offensive and irresponsible to ask for the public's time to comment on a rule proposed by an organization who, due to its important position in the market structure, needs to be trusted by the public but that currently can't be trusted as it's allowing at least one mathematical impossibility to exist within the market structure whilst, obviously, actively ignoring the risk this existing mathematical impossibility poses to the existing system in which they're operating and that the market relies on.
If adding a potentially flawed rule to such an important existing system, which it'll go on to degrade due to the lack of competence in those proposing it, is getting the cart before the horse to allow this rule would be akin to getting the cart, which you don't own, before the rumor of a horse which you also don't own.