Subject: SR-NSCC-2022-003
From: Michael Tomaino
Affiliation:

Apr. 20, 2022



I have a comment on the proposed rule in the subject line.  My comment:

The “rush to unwind in a stressed market scenario” *is* the risk that short-sellers take. Your proposed rule would obviously lower the risk associated with short-selling and in turn it would naturally encourage more and more naked shorting.  The impact of this rule would be to insulate the big players on Wall Street from the consequences of their own actions.

Unfortunately for the short-sellers you are currently trying to help: they KNEW the risk, the TOOK the risk, and now you are trying to help them avoid the consequences of taking that risk.

Sorry, I am not in favour of this rule change.

Michael Tomaino