Subject: SR-NSCC-2022-003
From: David Llewellyn
Affiliation:

Apr. 20, 2022

 


The market already lacks transparency and accountability for large institutions, so I'm disappointed this rule is being proposed.
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 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. This rule proposes the opposite of 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."
This is very frustrating to see rules like this being proposed that only favor reckless institutions. 




Thanks, 
David Llewellyn