April 20, 2022
As a retail investor, I am highly opposed to the Proposed Rule SR-NSCC-2022-003. I am extremely disturbed by the content of this proposed rule that would effectively allow for Failure To Delivers (FTDs) to continue and worsen, which can be abused by market makers and used in conjunction with naked shorting and dark pool trade routing to control and suppress the price of equities. These activities do not support free and fair markets for retail investors.
Please do not allow Security Financial Transactions, which create new methods whereby the financial obligations of FTDs get passed along instead of settled. This proposed rule is shorted sighted and allows for abusive practices where market makers are not held accountable for their failings. In order for the equities markets to be fair, market makers must be held accountable for their financial obligations, regardless of the short or long term consequences they face.
I request that this proposed rule be denied and that similar rules are not proposed in the future, as iterations of this have been rejected in the past and continue to be rejected by educated investors every time they resurface. The repeated attempts for such a measure to be passed after multiple rejections points to the potential desire for malpractice by market makers.