April 21, 2022
21 April 2021
File No. SR-NSCC-2022-801
To Whom It May Concern,
This ruling is essentially a revision of the NSCC-2021-10, which does absolutely nothing except assist the market to continue its current trajectory of kicking the can. I find the amount of ruling that have been in placed in the past two years to not be coincidental. I am sure the folks at the NSCC have the best interest for retail individuals, but it is ruling such as the SR-NSCC-2022-801 that baffles me.
If the bad short institutions, who lets be honest, is the reason why this ruling is trying to be implemented are undermining the integrity of the market, specifically derivatives using God knows what sort of leverage, the NSCC thought process is to propose a rule to contain the loan agreement. The same similar method on how we contain failure to deliver?
This does not solve anything. If securities are lent, and there are no due date for its return, so the securities continue to be lent, until the number becomes too great and cause a systemic issue, the NSCC should stop the bad actors and not try to contain it. The proposed rules and goals of this agency primary focus should be to protect retail investors, which have been getting the short end of the stick. This means that all securities must be settled and closed within a time frame. No work arounds. They should not be contained as this rule suggest.
In summary, this proposed rule is manure. It is a slap in the face to retail investors. I behoove you to not pass this ruling and I thank you for your time.
Sincerely,
Sam