Subject: SR-NSCC-2022-003

Apr. 20, 2022



This entire rule change appears to exist to protect market makers from naked short selling and the consequences of failing to deliver; implementing this change will fundamentally undermined investor confidence in operating markets. This is, at its core, attempting to change the rules to protect one side of a trade at the expense of the other side. Every single time a rule like this is proposed it is to protect those that have taken on risky trades from the consequences of those trades. This creates a moral hazard that encourages this risk-taking versus enforcing the rules that would inherently reduce this risk taking behavior. Implementing this rule will fundamentally undermine the market function and further reduce the world‘s confidence in the US market.