Subject: SR-NSCC-2022-003
From: James Richey
Affiliation:

Apr. 20, 2022



I would like to express my displeasure on the proposed rule SR-NSCC-2022-003. The market already lacks transparency and accountability for large institutions, so I am very 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.
This is 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 by any means? 


This is very frustrating to see rules like this being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations. 


Thank you. 


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James J. Richey 
  

What people call impossible 
is just stuff they haven't seen yet... 
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