Subject: File Number SR-NSCC-2022-003 comment
From: Michael Gorski
Affiliation:

Apr. 20, 2022


Hello, 


As a retail investor, this rule is against my interests. Failures-to-deliver need to be resolved with delivery of the underlying security. No other means of resolving an FTD should be allowed. 
If an actor fails to deliver, they should be obligated to locate the underlying security on the open market and deliver immediately. Any failure to do so should be met with daily punitive fines that are so punitive as to encourage closing the FTD rather than kicking the can. 


This rule is overly complicated and gives bad actors the ability to perpetually kick the can. 


Scrap this rule. It will not allow for honest price discovery, and it encourages bad actors to continue their bad bets and to hurt retail investors.