Apr. 20, 2022
To whom it may concern As a retail investor I am highly disturbed by the content of this new proposed rule, SR-NSCC-2022-003, that would effectively allow for Failure To Deliver to continue and worsen or at least become even more opaque. It will be exploited by market makers and banks. In light of the already massive illegal naked shorting and abusive dark pool trade routing to control and suppress the price on security trading, this would make the position for retail investors worse. As a Swiss and Europe Citizen I will lose faith in the American market if this rule is granted. 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. It allows abusive practices in which market makers are never accountable for their failings. This creates another risk to harm retail investors and it violates the rights for a free and fair market. A concerned Swiss citizen that is hoping for a fair American and international market, Urs Huber Virenfrei. www.avast.com