Subject: SR-NSCC-2022-003
From: Karim Nahed
Affiliation:

Apr. 20, 2022

 


To whom it May Concern: 



As a retail investor, I am highly disturbed by the content of this new proposed rule that would effectively allow for FTDs (Failure To Deliver) to continue and exacerbate. These FTDs are currently being abused by market makers and used in conjunction with illegal naked shorting and abusive dark pool trade routing to control and suppress the price on security trading. This proposed rule does not in any way benefit investors and in fact could be extremely harmful, which is antithesis to the entire supposed purpose of the SECs very existence. 


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 FTDs get passed along instead of settled. 
This would enable abusive practices to continue and for the growing complexity of the system to impact fair price discovery while allowing market makers to evade accountability for their failings. This is not acceptable and will harm retail investors and their rights for a free and fair market. 


Please remove this proposed rule and any future iterations that aim to undermine the functioning of fair markets, by allowing back-door proposals that allow FTDs to stay open indefinitely. Savvy and engaged investors will continuously reject these proposals every time they resurface. 


The mission of the SEC is to look out for the well-being of investors such as myself, so I would propose that you direct your attention to doing so. The SEC can start by banning Payment For Order Flow which is inherently harmful to retail investors and which unfairly benefits Market Makers and brokers who do not have investors best interest in mind. Another worthy target for your attention would be to shut down the abusive use of dark pools by market makers such as Citadel which has been used to undermine the true value of securities traded by retail investors and to suppress price discovery. 


Thank you in advance for your timely attention to this matter, and please live up to your obligations and help the investors from predatory behavior by financial institutions. 


Sincerely, 


KNAHED