Subject: SR-NSCC-2022-003
From: Mike Hemmes
Affiliation:

Apr. 20, 2022

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Re: Comments on SR-NSCC-2022-003

Unfortunately this rule is unacceptable as the market currently lacks transparency and accountability for institutions. This rule would further skew true market price discovery via onward lending and removes the infinite risk of naked shorting and removes the deterrent of very risky business practices.
        Market makers continue to have the upside advantage and then excessively naked short securities, laying waste to their targeted securities . It is clear that this rule does not contribute to a fair market.  Failure to deliver failure to delivers are heavily manipulated various derivative products  preventing these failure to delivers from reaching the 30 day limitation for when the security needs to be delivered.
        This rule only favors reckless behavior and must be reconsidered for fairness, retail investors, and fair market stability.

- Mike Hemmes, Lindenhurst, NY