Subject: Comment Against SR-NSCC-2022-003
From: David Olson
Affiliation:

Apr. 20, 2022



Good morning,

I’m writing as a sincerely concerned small business owner and investor about the proposed rule SR-NSCC-2022-003.  I am against this rule change and urge you to permanently table all current and future proposals of this kind.

When an organization makes a bet on short selling or lending of securities, it takes on risk.  That risk is a normal and necessary part of market structures.  If market makers, which already have incredible tools at their disposal to manipulate markets in their own financial interests, gain the additional ability to noviate transactions that are not in their favor for liquidity, then the necessary risk inherent in participating in market plays becomes nonexistent.

Risk is a necessary part of making market choices.  Without risk, players with enough cash could literally destroy businesses through short selling, naked shorting, FTD, and other manipulation.  The inherent risk in shorting is a necessary aspect of its inherent quality to balance markets and provide risk to decision making that could collapse entire industries if that risk is no longer present.

Again, I am registering my unwavering opposition to this proposed rule change and any and all future proposals of the same kind.

Sincerely,
David Olson
DO Music