Apr. 21, 2022
The current market lacks transparency and accountability for large institutions. As a retail investor, I'm disappointed and extremely concerned that SR-NSCC-2022-003 is being proposed.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 an unsafe and harmful business practice.This new proposal would become an outrageously unfair advantage for market makers, which excessively naked shorts securities, and all create infinite 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 various methods such as using derivatives, not allowing them to reach their 30-day mark where the security needs to be "delivered."This is very frustrating to see rules like SR-NSCC-2022-003 being proposed, as they only favor reckless institutions. Hopefully, the SEC will consider the words of retail investors on present and future regulations, as retail investors continue to get the "short end of the stick" throughout the investment world. I firmly believe SR-NSCC-2022-003 is an insult to anyone and everyone who has ever purchased a security in our markets. Through this new proposal, the NSCC would have you endorse their criminal activities under the illusion of fairness.This same policy has been proposed TWICE before under different guises and has previously been "shot down" or revoked. Large financial institutions are horrified that they might no longer have the option of taking risky bets and not facing the financial or legal consequences.It sickens me to see market makers and financial institutions propose such blatant exploitative methods repeatedly, just waiting for the day one of their biased and unfair proposals slips through. They think they are above the law, the consequences, and the investors they exploit.I would firmly ask that you deny the SR-NSCC-2022-003 proposal.As a retail investor, I implore you to take this threat to the very sanctity, fairness and transparency of our markets for what it is - a threat against every single retail investor. Please do your part and stop this. -- Kind Regards, Thomas A. Irons