Oct. 10, 2024
Good afternoon, As a concerned retail investor, I am writing to urge you to increase penalties on corporations that violate security trading rules. The current system needs improvement to better protect investors, maintain fair and efficient markets, and facilitate proper capital formation. I strongly support enhancing NSCC Rules 4, 18, and 22 to remove ambiguity and establish strict procedures for settling guaranteed transactions. This will create a level playing field for all market participants. Regarding NSCC Rule 22, I advocate for Option B, the "No Exceptions" approach, to ensure consistent application of rules and regulations. This "you broke it, you bought it" environment would hold defaulting members and their executives accountable for closing out positions, including potentially disruptive ones. Additionally, I want to add my voice to the support for including executive compensation clawbacks in the loss allocation process. This would introduce another loss-absorbing resource and encourage proactive risk management practices. These changes would strengthen the resilience of registered clearing agencies like the NSCC, supporting the overall stability of our financial markets and system. I respectfully request prompt action on these proposals, with similar adjustments considered for other relevant entities such as the DTC, FICC, and Options Clearing Corporation. I want a strong, stable, honest market to invest in as a young adult who is socking away for retirement. I don't want my retirement security to be at risk by not holding criminals accountable, providing waivers instead of penalties, and penalties just being a slap on the wrist. Thank you for your time, Brian Herrmann Chicago IL 60616