Subject: Comments on SR-NSCC-2022-003
From: Chin Lam
Affiliation:

Apr. 20, 2022

 



To whom it May Concern:
As a foreign retail investor I am gravely concerned by this new proposed (rehashed and repackaged) rule that would allow FTDs (Failure To Deliver) to continue and worsen, which can be abused by market makers and used in conjunction with illegal naked shorting to suppress the price on security trading. The proposed rule does not benefit individual investors. The playing-field has never been bigger in the world's financial system and this regulation will further widen the gap between the information individual investors receive, versus the data driven institutions. 
I would strongly urge the SEC to reconsider before implementing the Security Financial Transactions proposed in this rule, whereby the very real financial obligations of the FTDs get passed along to unknowing investors or financial institutions instead of settled. While the rule could provide short term stability, it also allows for abusive practices where market makers are never accountable for their high risk strategies. This is unacceptable as retail traders and it allows further damage done to retail investors as the regulation further "stonewall" violates our rights for a free and fair market. The manipulation needs to come to an end.
Please remove this proposed rule and furthermore, please do not try to propose something similar again in the future, as iterations of this have been rejected in the past and continue to be scrutinized by many investors who keep close eyes on the SEC, DTCC, NSCC before every rule gets passed as regulations. We as individual investors are already at a disadvantage against large financial institutions with many different arsenal at their disposal. Transparency and accountability is the much needed in this complex system.
The mission of the SEC is to safeguard the rights of investors, hence I would propose that you direct your attention to doing so. 
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
Oliver Lam