Subject: SR-NSCC-2022-003
From: Jeff Hudson
Affiliation:

Apr. 20, 2022




The market already lacks transparency and accountability for large institutions, so I am in complete opposition to this rule.
I've read every single page of legal jargon in the file and it is very clear what this rule proposes.
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 extremely 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. How does this rule contribute to a "fair" market by any means...? It does not represent the interests of the people.
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 infuriating to see rules like this being proposed that only favor criminal financial institutions. Hopefully you'll consider the words of retail investors with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years.