Apr. 20, 2022
Hello. SR-NSCC-2022-801 This document talks at length about risk, and risk mitigation. What if fails to address is consequence of the parties at fault. When you reduce risk, you remove liability. One can think of them as equal when in the stock market. The stock market is inherently risky, and removing that risk from one side, will remove their responsibility, liability, and consequences for their actions. Removing risk will continue to imbalance the stock market even further. If the NSCC did not want market disruptions, they should have stepped in a long time ago to prevent the lack of consequences on the behalf of banks, hedge funds, and financial institutions. If a retail investor is at risk of margin call or bankruptcy, they are not allowed these tools that are exclusive to the Big Players. Do you see that the document fails to mention retail, transparency or even "fairness" even once? Do you not see that this rule, will allow even more reckless plays from institutional players. If the price quickly rises in a stock, institutional players should pay the price for that stock, rather than using an STF to onward lend that stock. It exponentially increased share lending without accountability. The fact that a footnote states "not likely be compatible with regulatory requirements" shows you what kind of rule this is. Please heed the call of retail, take the stance against corruption.