Apr. 19, 2022
To whom it may concern, The following is my comment for File Number SR-NSCC-2022-003: The market already lacks transparency and accountability for large institutions, so I’m not only disappointed but shocked this rule is being proposed. It is a terrible rule that only rewards bad actors and leaves retail as the bag holder. It goes against the very spirit of what a free market should be. I've read every single page of legal speak in the file and have come to a clear conclusion. This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely, and in so doing, the deterrent of engaging in what is supposed to be a very risky business practice. It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. How does this rule contribute to a "fair" market by any means...? It doesn’t add up. FTDs are already "reset" through a variety of methods such as using deriviatives not allowing them to reach their 30 day mark where the security needs to be "delivered." This is very frustrating to see rules like this being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years and are essentially the future of this or potentially any markets moving forward. Best regards, DW