Apr. 20, 2022
To Whom it May Concern, I am a retail investor living in the United States. I would like to voice my extreme concern regarding proposal SR-NSCC-2022-003... SFTs (Securities Financing Transactions) sound exactly like naked shorts for FTDs (failures-to-deliver). If I'm not mistaken, naked shorting is illegal, so why should something so similar be allowed? This rule basically seems to allow for the bad actors on Wall Street to juggle their bad bets indefinitely. FTDs shouldn't even be a thing in a fair and transparent market, but the U.S. Stock Market is already dimly translucent and allowing this proposal to pass would make it truly opaque. In a fair and transparent market, accountability would be the driving force. Proposal SR-NSCC-2022-003 allows the bad actors to entirely ignore accountability which is the primary reason I believe this proposal (or any like it) should never be passed. I would urge the SEC to investigate the party(ies) that submitted this proposal as they are obviously already breaking the law and are trying to figure out how to continue doing so without repercussions. Sincerely, Robert Noakes A Truly Concerned Retail Investor