Subject: SR-NSCC-2021-010
From: Garrett Culbertson
Affiliation:

Feb. 13, 2022



I think this rule should not be passed. It facilitates short selling and disproportionately benefits institutional investors by allowing them access to a security lending procedure not available by other entities. Short selling on the market is already creating problems, this rule allows big players to perform abusive naked short selling and get covered easier. Liquidity is not a reason to allow an activity such as this, it will harm the long term price valuation of a security if short selling is used to "provide liquidity" for a trade. 


Garrett Culbertson