April 20, 2022
The rule appears to add additional complexity to an already over complex set of rules. Generally additional complexity is used to exploit retail traders to the benefit of Wall St and increases distrust in our financial markets.
It's unclear why this rule change is necessary and who is expected to benefit from it. In a system where we already have very limited control over excessive short interest and the various mechanisms to hide short interest, adding additional complexity and effectively reducing transparency regarding failure to delivers and short interest appears only to serve to protect large investors from the infinite risk of shorting to their benefit and at the detriment of retail longs.
Please re-consider this rule in its entirety. More transparency and less complexity must be prioritized.