Subject: File Number SR-NSCC-2022-003
From: Steve Barraclough
Affiliation:

Apr. 20, 2022

 


Good afternoon, 


As a UK citizen I hope my status as a retail investor is still taken into account, as these rules impact all who invest in the NYSE.  
The market already lacks transparency and accountability for large institutions, so I'm disappointed this rule is being proposed. 

I've read every single page of legal speech in the file and have come to a clear conclusion. 
This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice.
It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. How does this rule contribute to a "fair" market by any means...? I don't see it.
FTDs are already "reset" through a variety of methods such as using derivatives not allowing them to reach their 30 day mark where the security needs to be "delivered." 
This is very frustrating to see rules like this being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years.


The knowledge I have gained over the last 18 months of investing in the US stock markets, alongside these attempted rule changes are making me seriously consider whether it is safe to invest in the NYSE if I am a retail investor, as there seem to be no protections for ourselves, but relentless protection for large institutions that often seek to change the rules to suit themselves and escape punishment for wrong-doing. 


Kind regards,
Steve