Subject: SR-NSCC-2022-003 Comment
From: Derrick Song
Affiliation:

Apr. 20, 2022

 


Hello,
My name is Derrick Song, I'm a retail investor. The following is a comment on SR-NSCC-2022-033 that I found on social media that very directly and accurately represents my thoughts on this particular rule and I would like to use their comment as my own, with minor modifications: 

The market already lacks transparency and accountability for large institutions, so I'm extremely disappointed this rule is being proposed.
I've read every single page of legalese in the file and it is very clear what this rule proposes.
This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice.
It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. How does this rule contribute to a "fair" market by any means...? I don't see it.
FTDs are already "reset" through a variety of methods such as using derivatives not allowing them to reach their 30 day mark where the security needs to be "delivered."
This is very frustrating to see rules like this being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years.
Not only would I hope that this rule is not accepted as it benefits market makers and financial institution exclusively AT THE EXPENSE OF RETAIL WHICH ALREADY HAS LITTLE-TO-NO REPRESENTATION IN THE CONVERSATIONS WHERE THESE TYPES OF RULES ARE PROPOSED AND DESIGNED...... I would hope that the audacity to propose such an incredibly inequitable rule would expose whoever supported or proposed these rules to confirm themselves as an enemy of retail, enemy of the state, enemy of the country, and essentially part of what is effectively an organization of financial terrorism seeking to enrich itself on taxpayer dollars directly or indirectly. 
Acceptance of this rule would prove definitively that the NSCC does absolutely nothing to protect retail investors or the legitimacy of the American stock and/or derivative markets. Instead, the NSCC would have shown itself to completely ignore its mission statement and instead implement and enforce rules that benefit overrepresented institutions who represent the largest financial donors and lobbyists that interact with Washington - a corrupt, captured regulatory agency.