Apr. 20, 2022
Greetings, The following is my comment for File Number SR-NSCC-2022-003: The market already lacks transparency and accountability for large institutions and this rule furthers this lack of transparency. 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. 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? FTDs are already "reset" through a variety of methods such as using derivatives, which allows FTDS to go longer than the 30 day delivery period. This is very frustrating to see rules like this being proposed that only favor reckless institutions. Best, Brendan Tovar