Subject: SR--NSCC-2022-003
From: Bryn Feldmann
Affiliation:

Apr. 20, 2022

 





Dear SEC, 

(Sending this e-mail again as I just checked and the proposed rule changed version #). 

Rule: https://www.sec.gov/rules/sro/nscc/2022/34-94694.pdf 

As a retail investor I am simply astonished by the content of this new proposed rule that would effectively allow for FTDs (Failure To Delivers) to continue and worsen. The prevalence and existence of illegal Naked Shorting has been proven which can be abused easily by market makers and used to unnaturally suppress the prices of securities. This does not in any way benefit investors and in fact is extremely harmful and goes against the entire purpose of the SECs very existence. 

Confirmation by a former Hedge Fund Manager (Mark Cohodes) of the consistent, rampant practice of illegal naked short selling: https://www.youtube.com/watch?v=WUAfc4S3djU 
Former SEC Lawyer confirming the practice: https://www.youtube.com/watch?v=lB43u38BV8o 
Charles Gradante confirming Naked Shorting: https://www.youtube.com/watch?v=OChaTm0To1U 
You, the SEC, even said it yourself: https://www.sec.gov/comments/s7-08-09/s70809-4614.pdf 


Please do not allow SFTs (Security Financial Transactions) proposed in this rule. This is a systemic problem that has been created by over-complicating the system. There are extremely simple ways to allow for simplification, transparency, and trust to be restored - and this rule imposes the exact opposite of trust, simplification and transparency. The very real financial obligations of the FTDs will get passed along instead of settled. It allows for abusive practices to continue and allow market makers to never be accountable for their failings. This is not acceptable and creates an opportunity to harm retail investors and violates our rights for a free and fair market. 

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 rejected by educated investors every time they resurface. 

The mission of the SEC is to look out for the well-being of investors such as myself, so I would propose that you direct your attention to doing so. 

Be the change you wish to see in the world. Start fighting for a fair market now. Stop allowing rules that are so obviously malicious such as this one to surface. The sooner this happens, the sooner we live in a better, honest, uncorrupt world. 

~Bryn Feldmann, concerned retail investor.