Subject: SR-NSCC-2022-003
From: Kieron Kelly
Affiliation:

Apr. 20, 2022

 


Good day, 


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


The market already lacks transparency and accountability for large institutions, so im disappointed this rule is being proposed. 


Having read through the file, I have come to a clear conclusion.  


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. Which by itself, defeats the purpose of a free and open market. This is obviously a laughable concept for anyone who has any idea about how the US stock markets are run.  


It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting.  


FTDs are already "reset" through a variety of methods such as using deriviatives not allowing them to reach their 30 day mark where the security needs to be "delivered."  


It is very frustrating to see rules like this being proposed that favours recklessness with no thought as to how it will affect the woder markets. Hopefully, you'll consider the thoughts of retail investors in your decision making in regards to regulation in the markets, as your organisation's legacy would do well to heed.  


Regards, 


Kieron Kelly