Subject: SR-NSCC-2022-003

Apr. 24, 2022

 


Dear Sir or Madame, 


today I'm writing you this mail in the light of the possible introduction of SR-NSCC-2022-003. 
As a retail investor i am against this rule for the following reasons: 


It creates less transparency in an already confusing market. Big institutions will have access to this new SFT program, while retail investors won't have information about it or any chance to use SFTs. 


It also helps Market Makers which abuse their rights and engage in Naked Shorting dodge their obligations to fulfill a trade that is unfavourable for them. With the NSCC acting as a intermediary it reduces the risk for market participants which decided to take a trade with infinite risk. 
If someone engages in such practices they should be held responsible for the damage they could cause if the trade goes wrong, and not be bailed out. 


Furthermore this rule will worsen the problem with FTDs. The market already has a rampant problem with FTDs. With SR-NSCC-2022-003 this very problem would get bigger by the day. It creates an environment where market participants are not punished for creating FTDs, which can already be avoided through derivatives and so on. 


This rule is not acceptable and it creates an addiotional way to harm retail investors and also violates our right for a free and fair market. 


Please remove this proposed rule as it ultimately harms retail investors, gives big market participants a way of avoiding punishment for abusive behavior, and it prevents REAL price discovery in the market. 


Sincerely, 


A worried retail investor