Subject: File No. SR-NSCC-2022-003
From: Ryan Ng
Affiliation: none

April 24, 2022

The proposal as written appears to establish a new set of transactions that can be used to circumnavigate Failure To Deliver (FTD) reporting rules. If this rule is implemented it creates a new possible vehicle to grant an advantage for organizations with short interests over any entity or individual who is long the market. In a time where more and more individual investors are becoming wary of the stock market, this rule change could further push them from participations.