Apr. 20, 2022
As a retail investor who owns multiple shares of a heavily-shorted security, it is imperative that this rule does not pass. Those who endorse this rule want the SEC to abandon their mandate to protect investors and maintain fair, orderly, and efficient markets so they will rubber stamp yet another Rube Goldberg mechanism to subvert regSHO locate requirements. The SEC's mandate isn’t “liquidity at all costs." Fair and orderly markets need MORE locates and LESS borrowing so that purchasers of securities can be confident in their ownership of said security and whatever attendant benefits (i.e. dividends, voting rights) said ownership entitles them to. Additionally, implementing this rule will undermine the ability of market participants to discover the price of a security, as it essentially enables endless can-kicking by short sellers, who can then continue to engage in a recursive loop of short selling in proportions well beyond the publicly listed float of a given security. It rigs the market against purchasers by devaluing their investments. Just because some market participants got themselves into hot water doesn’t mean that the SEC should change the rules to protect them from consequences. Make the borrowers deliver on their promises instead of granting them overnight IOUs, lest you render said promises effectively worthless. Again, this rule cannot pass. Thank you for your time.