Apr. 20, 2022
To whom it may concern, This proposal is not in the interest of retail; the average user that government agencies should be looking out for. This does not lead to transparency or hold those who have put the market at risk accountable. The complexity of rules that govern our, supposedly, free and fair market are not created by retail, rather by wall street, big banks, and hedge funds. They use the complexity to their advantage. In other words: rules for thee, not for me. This rule is just another example of leveraging complexity to fleece over retail by keeping them ignorant. Quite frankly, it is the opposite of the story of Prometheus. In this timeline, we would have seen Prometheus steal fire from man to give it back to the surplus among the gods. This proposal offers protection to Goliath while spitting in the face of David. Are the odds not already stacked enough? This seems to fly exactly in the opposite direction of how our fair market is supposed to work, and correspondingly, gives bad actors yet another sanctioned venue for cheating the system. A venue that retail has zero access to. .The avoidance of market price discovery through onward lending is essentially the entire purpose of this rule. It removes that infinite risk of naked shorting entirely, and in so doing, the deterrent of engaging in what are supposed to be very risky maneuvers. It's all upside for bad actors, and all downside for those on the wrong side of their shorts. Presumably forever. We're talking about exponentially increased share lending without accountability for bad actors making poor choices and putting everyone else at risk. In what way is this right? In what way is this fair?