Subject: SR-NSCC-2022-003
From: Levon Davis
Affiliation:

Apr. 20, 2022

 



I am writing as an overseas retail investor, very concerned about the implications of the rule you proposed.
It is very clear to me that the rule in fact acts against the interest of retail investors, whom SEC is supposed to protect.
It does that by increasing possibility for avoidance of true market price discovery through continuous lending. It also significantly lessens the infinite risk of naked shorting. That practice, as I am sure you are aware, is by nature very risky and for a good reason.
Without that risk, the institutional investors are free to essentially gamble with taxpayers and retail investors money, posing systemic risk to the integrity of US stock market.
I consider that transparancy essential for a fair and sound economy, as well as for the democracy. 

I sincerely hope that whoever this concerns, will reevaluate their position and withdraw that ruling completely.