Subject: SR-NSCC-2022-003
From: John Philbrick
Affiliation:

Apr. 20, 2022



Hello,

This proposed rule does not address but undermines the issue of market transparency and naked shorting. By hindering natural price discovery in the case of naked short sellers, this rule simply reduces the consequences of reckless institutional naked short selling. This rule is anti-retail as it would provide yet another mechanism to be abused at the expense of non-institutional investors. When the illegal act of naked short selling occurs, the just response is not to propose rules that allow the consequences to be subverted.

Thank you