Subject: SR-NSCC-2022-003
From: gta N/A
Affiliation:

Apr. 20, 2022


This proposal does nothing to further protect investors and maintain fair, orderly, and efficient markets. 

This proposal would allow for additional methods for hiding locates and FTDs therefore making the market less transparent. 

This proposal leads to even less price discovery by allowing short parties to further hide their positions in increasingly complex and obscure vehicles. How does this do anything to promote fair and orderly markets? I don't believe in Longs having the ability to hide their positions anymore than I believe in shorts being able to do it. 

FTDs should not exist in this day and age with the available technology, period. There is no reason for it other than time dilation price manipulation. 


This proposed rule should be abandoned, and new rules making it more difficult to hide short and long positions should be pursued. 



Thanks, 


Greg Arnold