Subject: File No. SR-NSCC-2022-003
From: John Otterron
Affiliation: Retail investor

April 20, 2022

Here we have yet another attempt to obfuscate an already opaque market structure by creating yet another rule to circumvent the out come of what can best be described as poor behaviour from market participants.

Rather than address the behaviour they would have us allow a rule allowing them not only to continue abusing the stock borrow programs as they have been but then also give them a tool to avoid reconciling their balance sheets. Because at the end of the day, all complex instruments aside, the market is a balance sheet and the only way to maintain the integrity of our markets is to stop the enabling of insidious behaviours and hold the market participants accountable and responsible for their balance sheet.

Like troubled children, they have been allowed to wreck the car over and over again It is time to take the keys away and hold them accountable for their actions.

No more can kicking instruments for hiding and disguising obligations.