Apr. 20, 2022
I am a military veteran, a citizen, and future Dad. After the military, I became a retail investor, and now would like to make my thoughts about this proposed rule known. I am afraid that the SEC is not representing the best interest of ALL investors. With our help, I hope you can steer this ship in the right direction before it is too late. The complexity of rules that govern our "fair" market, are not created by Retail, rather by Wall Street, big banks, and Hedge funds, and they use the complexity to their advantage. This rule is just another example of leveraging complexity to fleece over retail by keeping us ignorant. This rule flies in the face of fair market mechanics, and gives unlimited power and scope to bad actors who would abuse such mechanics. It is set in place to "alleviate Fail To Delivers", but in action does nothing to eliminate them, and in effect protects the action of naked short selling, which is ALREADY ILLEGAL. This rule leverages the complexity of financial vehicles to put power in the hands of institutions, effectively safe-guarding them from their own bad bets. Passing this new rule would only further deteriorate the American public's faith in a "free and fair market". I urge you to withdraw this proposal immediately. For example: "NSCC understands that SFTs provide liquidity to markets and facilitates the ability of market participants to make delivery on short-sales, and thereby avoid failures to deliver, ‘‘naked’’ shorts, and similar situations. On a typical Business Day, The Depository Trust Company (‘‘DTC’’), an NSCC affiliate, processes delivery orders related to securities lending transactions on securities having a value of approximately $150 billion." Seems like these are not *supposed* to be fungible, yet this rule would make them exactly that. Thought exercise: $100 worth of Blockbuster Shares vs $100 vs Apple Shares. Can it be said that they are equal in value on any given day? I don't think so, one must consider company leadership, market cap, growth potential, etc. etc. That would be like saying every company is exactly the same (i.e. fungible) which certainly isn't the case in reality. This seems to fly exactly in the opposite direction of how our "Fair" Market is supposed to work, and correspondingly, gives the bad actors mentioned previously yet another sanctioned venue for cheating the system. A venue that Retail has ZERO access to. Thank you for taking the time to read this, I hope the SEC will make some major changes soon before it is too late.