Apr. 20, 2022
Hello SEC, I am writing to voice my opposition to SR-NSCC-2022-003 (NO TO SR-NSCC-2022-003). I am an individual/retail investor with multiple types of investment accounts, including mutual funds, individual stock, Roth IRA, and 401k between myself and my wife. I began investing in the markets under the guise of a “free and fair market”. I believed the market was built in such a way as to root out its own problems, that it would always regress back to true value. I believed this after witnessing 2008, as I thought that systemic changes were made to correct the failures in market structure that led to the Great Recession. I have been an investor for about a decade now, and I believed this fallacy for the first 8 years that I was involved in the markets. For the better part of the last two years, my eyes have been opened (further and further each day it seems) to the true corruption that is allowed to persist in the markets. The rule change SR-NSCC-2022-003 has already been proposed at least two times already. Sure, the title and some verbiage may have changed, but the substance remains the same. This rule prevents true price discovery. It allows for endless “can-kicking” of failures to deliver (FTD’s). In essence, it is the exact opposite of a free and fair market. I urge you to withdraw this proposal, and stop wasting resources on further regurgitations of this. The role of the SEC is to protect investors. This rule would allow protection for market makers by fleecing investors on the buy side of a naked short trade. Naked shorting and FTD’s (especially ones that are never closed or settled respectively) do material harm to both the investors who are long and the company trading publicly. Once again, I say NO to SR-NSCC-2022-003. Thank you, Michael Kalinowski -- -Mike Kalinowski