Subject: File No. SR-NSCC-2022-003
From: Manuela Brumm

April 22, 2022

As a taxpayer, citizen of the United States of America, and a retail investor, I urge the SEC to withdraw this proposal immediately and without delay.

This proposal benefits the retail investor in no way, shape, or form, and is a disgrace. This administration has done nothing to stop systemic risk, naked short selling, PFOF, or dark pool trading abuse by those who wish to take price discovery away from our free and fair markets.

Please do not allow SFTs (Security Financial Transactions) proposed in this rule, to create new and potentially endless layers of can-kicking to be allowed, whereby the very real financial obligations of the FTDs get passed along instead of settled. I can see how it provides stability in the moment, but it also allows for abusive practices where market makers are never accountable for their failings. This is not acceptable and creates an opportunity to harm retail investors and it violates our rights for a free and fair market. The manipulation needs to come to an end.

Please remove this proposed rule and furthermore please do not try to propose something similar again 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. What a colossal waste of time, mine and yours, to continue to have to repeat this song and dance over and over again.

The mission of the SEC is to look out for the well-being of investors such as myself, so I would propose that you direct your attention to doing so. This would best be accomplished by banning Payment For Order Flow which is inherently harmful to retail investors and which unfairly benefits Market Makers and brokers who do not have investors best interest in mind. Another worthy target for your attention would be to shut down the abusive use of dark pools by market makers such as Citadel which has been used to undermine the true value of securities traded by retail investors and to suppress price discovery.

Thank you in advance for your timely attention to this matter, and please live up to your obligations and help the investors from predatory behavior by financial institutions.

Sincerly,
Ela Brumm