Subject: SR-NSCC-2022-003
From: Paul Drambarean
Affiliation:

Apr. 20, 2022

 







To Whom It May Concern: 


As a retail investor I am very troubled by the content of this new proposed rule that would allow for FTD's (Failure To Deliver) to continue and worsen, which can be abused by market makers to control and suppress the price on security trading. I can't help but notice that you have acknowledged the existence of naked short selling in this filing. Naked short selling, as you are fully aware, is illegal. This proposed rule intends to make it less costly and less risky to commit this illegal activity by allowing for endless cycles of FTD's that are never truly resolved. Allowing for FTD's to be "resolved" by replacing the security to be delivered with an "equivalent" is counterfeiting. 



Please do not allow SFTs (Security Financial Transactions) proposed in this rule to create new and potentially endless layers of can-kicking to be allowed, whereby the very real financial obligations of the FTD's get passed along instead of settled. This rule allows for abusive practices where market makers are never accountable for their failings. This is not acceptable and only creates an opportunity to harm retail investors by violating our rights for a free and fair market. The manipulation needs to come to an end. 



Please remove this proposed rule, and furthermore, please do not try to propose something similar again in the future, as iterations of this have been rejected in the past and continue to be rejected by educated investors every time they resurface. 


Respectfully, a concerned investor.