Apr. 21, 2022
Hello there The following is my comment for File Number SR-NSCC-2022-003: The market already favors large institutions with the lack of transparency and accountability they have, and this rule will only further benefit large institution and hurt retail, and thus should be rejected. 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. These institutions have already destroyed countless business through short selling and this proposal would only allow them to continue doing this with absolutely no risk. It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting (which sooner or later is everyone except the 1%). 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." This is very frustrating to see rules like this being proposed that only favor these reckless institutions. There is a severe lack of rules that punish this reckless behaviour. The rules should be changed benefit the already disadvantaged retail not to hinder them further. For example FTDs should not allowed, shorts should be forced to close the moment there is a single FTD, or at least a percentage based fine that increases over time. Regards