Apr. 20, 2022
Good day, The following is my comment for File Number SR-NSCC-2022-003: The market already lacks transparency and accountability for large institutions, so I’m extremely disappointed this rule is being proposed. I've read every single page of legal speak 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...? FTDs are already "reset" through a variety of methods such as using derivatives, credit-swaps, and other asset-backed securities. Please review the amount of FTDs and you will see that there are billions of dollars of securities that fail to deliver each day. 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. Best, Josh Zimmerman Project Engineer Phone: (408) 727-6665 3350 Scott Blvd, Building 22, Santa Clara, CA 95054 www.kierwright.com
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