Apr. 20, 2022
To whom it may concern, I have great doubt that the proposed change (SR-NSCC-2022-003) will benefit retail investor rights at all and seeks to cause harm. This proposed rule change creates an unjust and inappropriate advantage for those institutions who pursue illegal trading practices. SR-NSCC-2022-003 creates a legal loophole to allow illegal trading practices such as naked short selling. This is essentially the "overnight reverse repo" program, but for FTDs. They can just borrow the shares they need anytime they want, whether they're available to borrow or not, and they can base the collateral requirements off of the INITIAL PRICE OF THE STOCK THEY NEEDED TO BORROW regardless of market circumstances or price action and "close out their positions" so someone else has to pay. It's another way to work around the legal system, once every 24hrs. And they can avoid the risk of loss that is associated with practices they pursue like shorting, Naked shorting, FTDs etc. Brokers would be given the freedom to "lend" SFTs created by the NSCC whenever, and charge whatever they want. If they want to charge each other zero dollars to lend those imaginary shares, they can. They're creating shares out of thin air "for the sake of liquidity" and giving it to Institutionalize investors. Leaving retail investors on the hook. Thank you