Apr. 20, 2022
To Whom It May Concern, The concept introduced by SR-NSCC-2022-003 where a "novation" in the form of "SFT"s for existing transactions directly jeopardizes the integrity of the markets. The proposed ruling even goes so far as to state: "NSCC understands that SFTs provide liquidity to markets and facilitates the ability of market participants to make delivery on short-sales, and thereby avoid failures to deliver, “naked” shorts, and similar situations." Any ruling that allows further loopholes for short sellers to skirt failure to deliver places a further imbalance in the markets that incentivizes abusive behaviors. I adamantly request that this proposed ruling be rejected as a means of protecting retail investors and to uphold values of a fair and balanced market. - Austin