Subject: Comment Regarding SR-NSCC-2022-003
From: Matthew Riddell-Ide
Affiliation:

Apr. 20, 2022

 


According to former DTCC insider, Susanne Trimbath PhD, "Primary Dealers reported over $300B fails (FTD+FTR) last week (lateat avail FRB data)." The continual erosion of transparency in our financial markets places the American economy (and quite possibly the world) in crisis. Allowing the continual can kicking of securities is an insult to any market participant. 


This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice. Completely removing the potential consequences of a market function serves only as an endorsement of the abusive shorting that takes place. 



FTDs are already "reset" through a variety of methods such as using derivatives not allowing them to reach their 30 day mark where the security needs to be "delivered." 

This is very frustrating to see rules like this being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years. 



Regards, 
Matthew