April 20, 2022
Dear SEC,
After reviewing the proposed rule. It seems that the naked short selling and FTD are wildly being used to gain advantage from retail investors. Instead of enforcing the root causes, this rule making FTD even more complex and cause great bias on price discovery. The part that Members able to netting position with other SFTs is complex and easy to get abused because the position value can be easily manipulated in the market using PFOF, dark pool and pumping scheme.
In short, I quite strongly disagree with this proposed rule as seeking market efficiency doesn't lead to fair and transparency market for retail investors.