Apr. 20, 2022
In regards, SR-NSCC-2022-003, I do not support such a change. Firstly, I feel strongly the proposed rule moves away from market transparency. There continues to large portion of the market (retail) that like transparency while participating in markets and this rule seems to contribute to the inequalities of data and access worsening transparency. Secondly, There are known risks when participants place short positions. These risks can lead to severe losses despite the risk participants willingly engage. One key component of the risk is potentially be in a position that requires the investor to repurchase shares on the “open market.” The proposed rule with SFT’s will lead to riskier and more use of leveraged position when the “consequence” of “open market” repurchases are removed. Again, I do not support this rule. Regards, Dan Marquardt