Subject: SR-NSCC-2022-801 (SR-NSCC-2022-003)
From: Cameron Pratt
Affiliation:

Apr. 20, 2022





To those of the SEC, 

I write to you this evening to denounce and recommend against the proposed rule change within the NSCC: SR-NSCC-2022-801 (Also known as SR-NSCC-2022-003, to my understanding). 



Like many "new" retail traders to the market over this past year, I have seen and experienced things that I would not have ever had anticipated when I decided to start throwing a couple of bucks in Robinhood, hoping to make a quick few back. It was therein I had my right to buy pulled right out from underneath me by said broker. I felt violated as a consumer, and small in my section of Main Street that I know only too well as a 26 year old trying to find their way through these odd times. So - and pardon my language - I started to give a damn. 

Thankfully my family wasn't hit hard by the 2008 financial crisis. I was blessed to be part of a family with steady, fair-to-upper middle class jobs. Though, in rural Vermont where I resided it didn't take long to see those less fortunate than I be down on their luck more-so than they already were. As I grew up I began to understand the root causes of such an event - the negligence of parties involved all too known at this point to revisit. That's the magic word though, isn't it? Negligence. Yes, we all suffered at different rates back in '08. More recently we have all suffered again at a once in a century pandemic that continues to rattle our cages of sanity. I ask myself - how many of these "once-in-an-X" events will I experience in my lifetime? Why has my generation been dealt this hand? The answer to that question, I believe, lies with the negligence maintained by those with liquidity power in our society. 



Wherein negligence is the disease, accountability reigns as the panacea to detrimental actions. When a debt isn't paid, recompense is still collected - or so I believed until I discovered the nature behind Failure to Delivers in the market. For the life of me, it's infuriating to see that debt can be compounded and pushed off down the line. We all know paying off a credit card with a credit card is a massively unwise idea, and yet the practice runs rampant in the areas where the biggest players of actionable consequence reside - Wall Street. 



I was raised to believe that under the proper circumstances debt can be a good thing as it pertains to capitalistic ideology. This I understand. But, debts are paid. Paying a debt with debt is destined to be an ouroboros where the consequences are passed on to parties not part of the initial transaction. It is not fair, and it is not right. 



Now it would seem that this rule SR-NSCC-2022-801 (SR-NSCC-2022-003) would institute a mechanism by which Failures to Deliver can be passed further down the chain and render a large part of the responsibility to cover said obligations by the initial party as null. This is antithetical to the financial philosophy that I have come to understand within this country as "the right way to do things." After all, I would be fined - perhaps imprisoned - if my debts were left unpaid. As would my friends, and their families too. We, the people, don't have the luxury of carrying enough cash to consider these penalties as "the cost of doing business." I, the retail trader, should be on the same playing field as those parties who carry power in the design of our monetary faith. 

This rule proposal is a slap in the face to all who have been responsible with their finances. It pains me to see that such major parties are leveeing themselves in support of such a rule, as it only confirms what I have suspected for some time now - I am playing a rigged game. And, as someone who will depend on the market to ensure their future as I continue to grow older, it is important to me that the SEC recognize and acknowledge that rules proposed should be towards the benefit of all and not a mere select few simply because their wallets are larger than George Costanza's. 



Therefore, I do not condone the rule proposal SR-NSCC-2022-801 (SR-NSCC-2022-003) and suggest it be stripped from consideration moving forward. For I may be but one retail investor, but my word should count just as much as the multimillionaires who govern our economy as they do. 

I thank you for your time, and bid you a fine evening. 



Sincerely, 
-Cameron Pratt, 
Retail Investor, Vermont