Subject: File No. SR-NSCC-2022-003
From: Harun Krishnan

April 20, 2022

I have a couple of issues with this rule coming into effect.

This rule is not in favour of retail or a fair market . If institutions are able to borrow shares without locating them for a fee, this power can be abused to short companies more than the float, if they have the necessary funds or large institutions backing them. There have been incidents in the past where this has happened, namely overstock, only difference is this rule will enable such behaviour even more.

If this the implementation approach for securities lending/borrowing currently undertaken by the SEC, when Blockchain exchanges are implemented, will this rule carryover? It defeats the entire purpose of a ledger based system.

This feels like enabling PFOF with additional steps, so I am against this rule. Hoping the sec will consider this.

P.S - impossible to add international phone number