Subject: SR-NSCC-2022-003
From: Tim Howarth
Affiliation:

Apr. 20, 2022



The following is my comment for File Number SR-NSCC-2022-003:

The market currently lacks transparency for the retail investor and and favors institutions. This proposal would further eliminate the transparency necessary for a fair market.

I've read the document and it is very clear what this rule proposes.

This rule  decreases true market price discovery. It removes the risk of naked shorting and responsibility for such actions.

It promotes and rewards the practice of naked shorting for financial gain while eliminating responsibility and accountability further handicapping retail investors. How does this promote a fair and equitable market?

FTDs are already "reset" through a variety of questionable practices such as the use of deriviatives and not allowing them to reach their 30 day mark when the security would need to be delivered.

It is frustrating when rule proposals favor institutions. It is my hope that you will consider the the retail investor regarding this and future proposals. As many more resources have become available for educating oneself on market practices over the past couple years it is becoming apparent that the market lacks transparency and is in need of changes but not of this kind.

Thank you.