Subject: File No. SR-NSCC-2022-003
From: Russell Lilly
Affiliation: 004407009056

April 22, 2022

This rule is a clear attempt to launder illegal naked shorts and FTDs. The DTCC and the NSCC both know there are billions upon billions (possibly trillions) of dollars worth of Naked Shorts, FTDs and the like that need cleared. This rule is written to circumvent that requirement. Brokers, hedge funds and the like have acquired debts they do not (or cannot) want to pay. A perfect example is Citadel owing (per their 2021 statement) over $65 billion in securities sold, not yet purchased, at fair value. So, rather than pay their debts like the rest of us, they make new rules to avoid them. In the process this will be the largest robbery of assets in world history. Comment on this rule has been pulled twice and this is the third attempt to push it through. Yet no amount of revising can change the fact that this rule allows hundreds of billions of dollars to go unpaid while harming retail investors, retirement funds, mutual funds, and others. This is the 1% making rules because they made bad investments and want us to pay for it. If I attempted a move like this, it would be considered money laundering and I would be charged with a felony offense. Yet, I dont have the power to simply change the rules to benefit self. The passage of this proposal would give hedge funds, brokers, banks, and many others an even greater advantage over retail while further suppressing market transparency.