Subject: SR-NSCC-2022-003
From: Phil Marler
Affiliation:

Apr. 20, 2022

 

To Whom it may concern 


As a retail investor I find the content of SR-NSCC-2022-003 deeply alarming. This regulation would allow large financial institutions to hold fails to deliver indefinitely. the only outcome of such a rule change would be the weakening of regulation SHO, and allowing naked shorting to continue unabated.
If enacted, this rule change would put the investments of many retail investors at risk as it will allow the dilution of a companies stock (by financial institutions naked shorting "for the purposes of liquidity"- despite the fact that 50% or more of trades may be being processed in dark pools, if they want liquidity why not let them hit the market rather than internalising?), without the issuers approval or knowledge. 
There are already major problems with current market structures that allow for significant disconnect between stockholders and accurate price discovery, are access to their shareholders rights. 
Please do not allow this rule to pass. This will not benefit retail. In the long run this wont benefit the markets either, further can kicking can only worsen the situation. 


Regards
P