Apr. 21, 2022
Good day, The following is my comment for File Number SR-NSCC-2022-003: The US-stockmarket already lacks transparency and accountability for large institutions, so I'm disappointed this rule is being proposed (again!). I've read every single page of legal speak in the file and have come to a clear conclusion. 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. It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. How does this rule contribute to a "fair" market by any means...? I don't see it. FTDs are already "reset" through a variety of methods such as using deriviatives not allowing them to reach their 30 day mark where the security needs to be "delivered." We need stricter delivery rules, not more lending, netting and resetting. I cannot see why "Liquidity" has to always come before "price discovery". If nobody sells and somebody wants to buy, he has to offer more until somebody sells. Thats normal supply and demand and that's the way it should be! These lending, netting, SFT shenanigans effectivly turn off price discovery and the market becomes completely fake and driven by big players. 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. Kind regards, Sebastian Schleicher