Subject: SR-NSCC-2022-003
From: Daniel Miller
Affiliation:

Apr. 20, 2022


Good morning, 
My name is Daniel Miller, I have been active in the stock market for 6 years now. Below are my comments and grievances in association with SR-NSCC-2022-003 


In a market where internalization, payment for order flow and many other mechanisms exist that restrict, influence and manipulate the market, it is disappointing that yet another rule is being proposed that would further rid the stock market of price discovery through onward lending. 


This rule change will also remove the infinite risk that investors expose themself to when engaging in risky behavior such as naked shorting. How does a rule that only encourages, by removal of risk, the excessive shorting of securities and companies to the point of bankruptcy. 


Failure to Deliver (FTD’s) are already adjusted and reset through the securities derivatives. It is quite convenient that these mechanisms exist that allow ANYONE to fail to deliver a security that is promised and essentially “kick the can” (push the problem) indefinitely. 


This is the third time that this rule has been proposed. Is there a reason that even with sufficient pushback to prevent this twice, you have the audacity to push a new rule change on retail investors that only aids in removing yet another influence retail can have on price discovery. 


Please consider the ramifications of the influence you are equipping the elite financial dictators of our economy with. 


Free and fair markets, 
Dan Miller