Apr. 20, 2022
Dear Sir/Madam, The following is my comment for File Number SR-NSCC-2022-003: As a retail investor based outside of the U.S, I feel as though the U.S. market already lacks transparency and accountability for large institutions, so I'm disappointed this rule is being proposed (again). This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite (not to mention illegal) risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice. It incentivises market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. I cannot see or understand how this proposed rule can in any way contribute to a "fair" market. FTDs are already "reset" through a variety of methods such as using derivatives and not allowing them to reach their 30 day mark where the security needs to be "delivered." It is incredibly frustrating to see rules like this being proposed that only favour reckless institutions. My faith in a fair and honest U.S market is already wafer thin, this proposal does nothing to convince me that I should continue to invest in U.S securities. Hopefully you'll consider the words of retail investors more with your decision making on regulations.