Subject: SR-NSCC-2022-003

Apr. 19, 2022

 



If the avoidance of market price discovery through onward lending is essentially the entire purpose of this rule. It removes that infinite risk of naked shorting entirely and in doing so the deterrent of engaging in what is supposed to be a very risky business. It's all upside for these (what I'd call criminals), and all downside for those on the wrong side of their shorts. Presumably forever. 


The SFT converts all old obligations into new ones so whatever rules and regulations that pertain to the underlying security and/or participants are voided. In footnote #20 it admits to this when it says that a direct service would "not likely be compatible with regulatory requirements", implying that this indirect transaction clearing service "avoids" those requirements. 



In the above they're literally stating it would not be per regulation and for good reason. I'd say this is not only a heinous law for retail and the good people that drive this country but also for smaller companies going public dealing with the monopolies that work with MM's and SHF's to short these emerging companies into the ground. If there is no inherent risk in engaging in these what should be illegal activities then what stops them? It just becomes a money printer for market makers, hedge funds, SHF and big banks, all at the expense of the everyday people, the retail investor. 


I'm sure millions of others, myself included, would not stand for this passing. I'd trust you collectively agree to have this withdrawn/thrown out and stop letting the big market makers, banks, hedge funds and short hedge funds who're ironically private for profit corporations continue to morph the financial regulations in their favor. (Conflict of interest, anyone?) 


Thank you very much for your time if you read this, honestly. 


Ryan Freeman