Subject: SR-NSCC-2022-003
From: Matthew Gill
Affiliation:

Apr. 20, 2022

I would ask that you deny the SR-NSCC-2022-003/801 proposal. The current market lacks transparency and accountability for institutional investors and their self-regulated organizations that lobby for these rules. This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of shorting (naked or otherwise) entirely and in so doing, the deterrent of engaging in what is supposed to be an unsafe, unlimited risk, illegal for most all market participants, and generally harmful practice.

We have an exuberant amount of complexity in rules that govern our ‘fair’ market, which are created by Wall Streets, and they use the complexity to their advantage. This rule is just another example of leveraging complexity to defraud retail by keeping them ignorant.

When we as a society are so focused on trying to benefit from, and even encourage, the failures of others we have failed ourselves. 


Thank you for your time in reviewing this comment,






Matthew Gill
Project Manager