Subject: SR-NSCC-2022-003
From: Danciu Razvan
Affiliation:

Apr. 22, 2022

 



To whom it may concern, 





As a retail investor in the U.S. Stock Market from Romania I am highly disturbed by this rule and I hope the U.S. Securities and Exchange Commission repeals this rule as soon as possible. The market already lacks transparency and accountability, so I am disappointed this rule is being proposed in the first place. 


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 doing so 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 ? 


Failure to deliver is already "reset" through a variety of 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 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. 






Thank you and have a great day, 
Razvan Danciu