Apr. 20, 2022
To whom it may concern, The following is a comment for File Number SR-NSCC-2022-003: From my perspective as a retail investor that believes in a free market and fair/consistent/level playing field for all, I would like to say the following regarding SR-NSCC-2022-003. The market without question already lacks transparency and accountability for large institutions, so I’m genuinely truly disappointed this rule is being proposed. I've read every single page of legal speak in the file and it is very clear what this rule proposes and how it is designed to benefit large institutions at the expense of individual investors. This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely; in so doing the deterrent of engaging in what is supposed to be very risky business practice is mitigated. This is designed to further reward market makers (who excessively naked short securities) and further places those on the wrong side of their shorting at an additional disadvantage. How does this rule contribute to a "fair" market by any means? The answer is simple. It does not, by design. FTDs are already "reset" through a variety of methods such as using deriviatives not allowing them to reach their 30 day mark where the security needs to be "delivered." It is beyond frustrating to see rules like this being proposed which only favor reckless institutions and harm retail investors. I, along with hundreds of thousands (if not millions) of retail investors sincerely hope that we can count on this not being implemented. Do the right thing for all of us who’ve ventured into the market as individual retail investors, enhance our market transparency, and help restore our faith in it. Thanks for your time. Sent from my iPhone