Apr. 20, 2022
Hello, I am very concerned about this new proposed rule, specifically this statement at the heart of the proposal: "NSCC understands that SFTs provide liquidity to markets and facilitates the ability of market participants to make delivery on short-sales, and thereby avoid failures to deliver, “naked” shorts, and similar situations " It is appalling to me that the NSCC, through this proposal, is trying to enable "naked" shorts rather than actually address the inherent market structure risk they pose and place rules to prohibit, discourage, and eventually abolish the market practices that take advantage of flaws in the current market structure. Additionally, this introduces another element of opacity in the market further diminishing what should be a transparent market. This is not the first time a similar proposal has come to this stage, and each time it has been found to be self-serving for those within the market who have taken advantage of the failings of the market structure, rather than actually trying to address the underlying market issues that allow these self-interested individuals/firms to take advantage of retail investors. This proposal does not improve market transparency, nor stability, and instead is a blatant attempt to pretend like "naked" shorts are just a part of the market that is here to stay. If this proposal is passed, "naked" shorts and failures to deliver will not be reduced and instead would become common practice within the market. At that point, the legitimacy and stability of the market would come under serious strain and scrutiny, and I fear that this would lead to catastrophic results. Please consider these comments and reject this proposal, as has been done with previous similar proposals. It is important that this is done to protect retail investors and the market's legitimacy. Again, I implore you to think carefully about the long-term implications of such a proposal, as they would surely be catastrophic and affect the lives of millions of people. Sincerely, Devin Saywers