Apr. 20, 2022
I look around and I see the brokers loaning out the shares owned by the small investors without their consent or in many cases even their knowledge. I consider what the results must be when they vote their shares or recall them to paper: the shares must exist no matter what. This rule you have proposed weakens short sale protections so badly that I see you, the SEC itself in grave danger of falling by the illegal activity it is designed to tolerate. To protect the integrity of the SEC's own insurance, SR-NSCC-2022-801 must not stand. Things have been set in motion that cannot be recalled again. A great storm is coming and the foundations will be shaken, and all that is not strong may pass away. Do not undermine your own foundations. The SEC's insurance must not fall. You must do whatever is necessary to protect the investments of small investors from being wiped out for no fault of their own; therefore you must crack down on outsized short positions that can sink entire brokers, not encourage them.