April 9, 2021
I am in support of the proposed SR-NSCC-2021-801.
I believe this ruling will help to increase accountability and transparency for those who engage in the short-selling/stock borrowing program.
In my opinion, the risk of the proposal not passing is significant. It is increasingly clear how intertwined the financial and securities industry is as seen with the recent Archegos liquidation. The ruling will help lower the probability of similar events in the future.
There also needs to be a review of penalties for multiple securities violations. As it stands, there is no incentive for bad actors to stop as long as profits outpace potential violation fines.
Thank you,
Alvin Ly