Subject: SR-NSCC-2022-003
From: Anders Rekve
Affiliation:

Apr. 20, 2022


To whom it may concern,

For the proposed rule change, I have the following comment:

As I see it, the fundamental function of the capital markets is effective capital allocation through the supply and demand function and price discovery. The proposed rule change interferes with the fundamental purpose of the marketplace. There are already significant issues with the current structure of the system in that respect, not to be detailed here. I refer to competent information venues available to retail investors on the subject, such as the statements and opinions of Dave Lauer of Irvin Finance, or Dr. Susanne Trimbath, or formed SEC Branch Chief Lisa Braganca on topics relating to the subject rule change and the Gamestop stock situation.

The US financial system relies on trust. By allowing a failure (Failure To Deliver) to exist, even making its existence less consequential for the parties to the failed trade, then what trust can be placed upon such a system?

Further, the system is already characterized by retail investors being structurally disadvantaged vs. institutions. This rule proposes a change that would reinforce this situation. It is for the benefit of the few to the disadvantage of the many. This does not hold to democratic principles.

Best regards,

Anders Rekve
Ph.D. candidate, Building Information Modelling
Department of Civil and Environmental Engineering, NTNU