Subject: SR-NSCC-2022-03
From: Robin Radermacher
Affiliation:

Apr. 21, 2022

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Dear ladies and gentlemen,

The following is my comment for File Number SR-NSCC-2022-03

I am writing as an overseas retail investor, very concerned about the implications of the rule you proposed.

After  going through the file twice, it is very clear to me that the rule in  fact acts against the interest of retail investors, whom SEC is supposed  to protect.

It does that by  increasing possibility for avoidance of true market price discovery  through continuous lending. It also significantly lessens the infinite  risk of naked shorting. That practice, as I am sure you are aware, is by  nature very risky and for a good reason.

Without  that risk, the institutional investors are free to essentially gamble  with taxpayers and retail investors money, posing systemic risk to the  integrity of US stock market.

What  we need is more transparency in how stock market works to level the  playing field between retail and institutions, especially considering  the widening wealth gap and soaring inflation, among other problems our  society faces. The proposed rule acts in the opposite direction.

I consider that transparancy essential for a fair and sound economy, as well as for the democracy.

Having  said all that, I sincerely hope that whoever this concerns, will  reevaluate their position and withdraw that ruling completely.

With kind regards

Robin Radermacher