Apr. 20, 2022
To whom it may concern, As a retail investor, I totally oppose the changes proposed by SR-NSCC-2022-003. Failure to delivers (FTDs) harm true price discovery. If a security isn't available to purchase at some price, then the price must go up until a security is available to purchase at some price. That is basic market economics, and this rule seeks to subvert this by enabling the delivery of FTDs to be further delayed. To me, this rule is an attempt to legalize fraud in our stock market, and I find that completely unacceptable. The proposed rule change reduces market transparency via convoluted rules that only benefit major wall street players while simultaneously going against the interests of retail investors like myself. In a free and fair market, FTDs would not exist. Any rule that seeks to enable more FTDs, or to delay or prevent their delivery, is a rule that moves the US stock market away from a free and fair market. If you have any questions about what I have written, please do not hesitate to contact me for more information. Thank you, Michael Himes