Apr. 20, 2022
Good day This is my comment for File Number SR-NSCC-2022-003: I've read the entire file and have come to the conclusion that his 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 very risky business practice. This is like changing the rules of the game in the middle of the game just because someone does not want to lose. 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? FTDs are already reset through a variety of methods such as using derivatives not allowing them to reach their 30 day mark where the security needs to be "delivered." It is frustrating to see rules like this being proposed. This rule only favors 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. The market already lacks transparency and accountability for large institutions, so i'm disappointed this rule is being proposed. What the market needs is less complexity and this rule will do the opposite of that. It is another rule to make the markets more complex and difficult to understand for the retail investor and does not benefit retail investors at all. Markets need to be simple and transparent to be effective. More complexity and rules like this mean a less effective, transparent and ultimately less fair market for all participants. Kind regards Rickey