Apr. 20, 2022
Regarding the proposed change SR-NSCC-2022-003: Self-Regulatory Organizations; National Securities Clearing Corporation; Notice of Filing of Proposed Rule Change to Establish the Securities Financing Transaction Clearing Service and Make Other Changes. Nothing the NSCC has done has been in the interest of a fair and stable market. The failure to delivers have skyrocketed. Numerous companies have short positions that are well beyond what they should be (naked shorts) and several have floats that are more than 100% of the issued shares (synthetic shares). These are facts. So now they would like to introduce another layer of complexity to further obfuscate the shady trading practices of their members. Obfuscation is what the NSCC does, it is it’s sole purpose. Dark pools were intended to allow corporations and other large organizations to buy or sell large blocks of shares without negatively or positively effecting the share price. However, even Gary Gensler the SEC chair noted that the vast majority of retail market orders go to dark pools. Which is not what they were intended for. The NSCC has shown repeatedly it will not allow a fair market. Until it’s member close their open positions, no rule changes regarding short positions should be allowed. In addition, all retail market orders should be required to go through lit exchanges. Regards, Dave Hamel