Apr. 20, 2022
Good Day, I am a retail investor, and the following is my comment for File Number SR-NSCC-2022-003: The market already lacks transparency and accountability for large institutions, so I am disappointed that this rule is even being proposed. I have read the proposed rule in its entirety, and I am vehemently opposed to this proposal. This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk associated with short-selling, and in doing so, it removes the deterrent of engaging in what is supposed to be a very high-risk strategy. This proposal is all-upside for those engaging in naked short-selling, and all-downside for any companies and investors targeted by that practice. FTDs are already 'reset' through a variety of methods such as derivatives, not allowing them to reach their 30-day mark which requires the security to be delivered. Rules like this only serve institutions and do not protect the retail investor, and expose retail investors to additional abuse by powerful firms engaging in exploitation of market mechanics. The complexity of the rules that govern our market is not accidental; the rules are designed such that institutions are able to leverage that complexity to gain unfair advantages over the retail investor. This proposal is just another avenue by which institutions would fleece retail investors. Withdraw this proposed rule (SR-NSCC-2022-003), and do not propose subsequent variations with like-intent. The proposed SFTs only exacerbate the FTD problem, which, as you are no doubt aware, in this modern-era of high-powered computers and near-instantaneous access to data, is a problem that only exists because it is convenient and profitable for the large institutions that benefit from it. Respectfully, Scott Green