Apr. 20, 2022
Hello, Please veto/cancel/end SR-NSCC-2022-801. This is the same thing (essentially) as SR-NSCC-2022-003 that I emailed about earlier. This proposed rule change seems to further insulate bad actors from the consequences of the riskiest and most reckless behavior within our markets today. The inherent risk of carrying massive overleveraged short positions with significant borrowing fees that have the potential for infinite loss while piling up massive amounts of FTD's should be deterrent enough for market participants beyond specific circumstances. Instead, thanks to all the unethical smoke and mirrors, intentional overcomplexity, multiple avenues for rehypothecation, obfuscation and non-disclosure; this trading strategy has become the defacto law of the land in modern equity markets. To approve this rule change is to make the statement that "privatized gains and subsidized losses" are a very real thing. It would illuminate a big flashing sign to the world that our markets are nowhere near "free and fair" and that price discovery will always be controlled by those with the power to pay "cost of doing business" .002% fines and who can lobby to empower those who can enact lopsided rule changes such as SR-NSCC-2021-803. The market should be a zero sum game for EVERY participant, not just disadvantaged retail investors. This rule effectively creates a darkpool for the short party during a short squeeze or forced share buyback (dividend, recall, etc.) It allows them to pay their debt in cash, based on daily share price, instead of buying shares on the market, which would increase the share price. NSCC is recognizing that predatory short attacks are becoming unsustainable, and they want to take the squeeze payout before retail investors can get it. They're offering to take on the short parties' debt so it can be paid off over years instead of all at once. DTCC/NSCC gets the money, retail gets the shaft, and SHFs get to erase billions of dollars in losses overnight. Thank you, Dana William Kuehneman