Apr. 19, 2022
Hello SEC, I am writing to you as a concerned retail investor and advocate for free, fair markets in the U.S. SR–NSCC– 2022–801 is objectively bad for transparency and runs counter to the idea that in a capitalist society, you can win AND lose. A simple reading of this document seems to me to say that the NSCC does not like the regulations imposed by Basel III - implemented because of the actions of these same market participants in 2007-2009 - and wants to change it to suit their own interests, and those of its members, in the supposed name of market stability. My faith in a free, open market is severely shaken, if not completely broken, when rules like this are proposed. If a market participant makes a "bad bet" they need to face the consequences of the actions they have taken. We should not support rules that allow bad behavior in our markets, allows parties to wiggle out of large capital loses, all while doing so with no public transparency, which is exactly what this rule does. It allows certain players to get out of the responsibility they have to make good on investments that do not play out how they intended. Basel III rules were put in place to protect market stability, this rule seeks to water down that regulation and protect large banks, broker/dealers and other large institutional market participants from the consequences of their own actions. For the reasons stated above, I urge you to reject adoption of this rule. Do the right thing, in the right way. Sincerely, Leonard Ford