Apr. 20, 2022
To whom it May Concern: I want to express my concerns about the newly proposed rule SR-NSCC-2022-003. As a European investor who has been actively involved in the American stock market for over two years, I'm deeply saddened to see a new rule being proposed that is counterproductive to a healthier and fairer market system in the long term. The rule SR-NSCC-2022-003 essentially incentivizes the endless continuation of FTD's ( Failure To Deliver ) as it allows large market participants to negate the obligation to buy back borrowed stock. This engages manipulative activity and will ultimately lead to less market price discovery through onward lending. It takes away the risk that goes with shorting and promotes an unleveled playing field between retail investors and institutions. This rule especially gives extra leverage to the market makers who are already in possession of various 'tools' to undermine real price discovery such as naked short selling, dark pools and Payment For Order Flow. By implementing these SFT's (Security Financial Transactions) you're taking away much needed transparency on short selling practices and this goes against your mission to protect retail investors. I hereby ask you politely to take my comment into consideration and refuse the proposed rule. Retail investors deserve an open and fair market system and it's your duty to provide this for us. Sincerely A Concerned Investor