Subject: SR-NSCC-2022-003
From: John Munro
Affiliation:

Apr. 20, 2022

 


This rule does nothing but add additional layers of potential fraud and ensure that our current illusion of a free and fair market remains just that, an illusion. By permitting SFTs as an instrument that can be used to avoid settling FTDs this will serve only to protect those engaged in risky and abusive market practices, those rich enough that they can pay a fee to avoid playing by the same rules as other market participants. Abusive short selling practices interfere with accurate price discovery and present a systemic threat to the legitimacy of our markets. Proposed rules such as this show a clear intent to protect the perpetrators of this abuse and are a dereliction of the SEC's duty to protect all participants and the market at large.