April 20, 2022
Good day,
The following is my comment for File Number SR-NSCC-2022-003:
The market already lacks transparency and accountability for large institutions, and I'm disgusted by this rule that is being proposed.
I've read every single page of this document and have come to a clear conclusion:
This rule would increase avoidance of true market price discovery through onward lending. It also removes the risk of naked shorting entirely by providing an alternate vehicle to delay or avoid delivery using \"SFT's\" or Securities Financial Transactions, and in so doing the deterrent of engaging in what is supposed to be very risky business practice.
It offers only upsides for market makers which excessively naked short securities, and only downside for those being shorted. How does this rule contribute to a \"fair\" market in any way?
Failure To Delivers are already \"reset\" through a variety of methods
Using derivatives to prevent them (FTD's) to reach their 30 day mark where the security needs to be \"delivered\" is a relatively straight-forward example.
This is not only insulting to retail investors, but completely detrimental to the 'fairness' of investing markets to have rules like this being proposed that only favor reckless institutions.
These markets are supposed to be regulated to PREVENT this kind of behavior, but instead rules are put in place to further convolute the system, providing complicated loopholes to further obfuscate the level of systemic manipulation and corruption that has continued for too long.
Perhaps with further retail involvement, as we continue to shine light on the areas that require the most reform, you would begin to consider the rules and provisions that make markets truly fair for everyone involved and not just a select few.
As a human species, we can do better than this.