Apr. 20, 2022
File Number SR-NSCC-2022-003: 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 it is very clear what this rule proposes. 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. Thank you!