Subject: SR-NSCC-2022-003: WebForm Comments from Christopher A Tutek
From: Christopher A Tutek
Affiliation:

May. 10, 2022


May 10, 2022

 Hi,
My name is Chris, and as a concerned investor in the markets I wanted to raise a extremely significant concern.


The following is my comment for File Number SR-NSCC-2022-003:


The market already lacks transparency and accountability for large institutions, so im disappointed this rule is being proposed.


This rule would increase avoidance of true market price discovery through onward lending. It also removes the risk of shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice.


It's all upside for institutions which excessively 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...? I don't see it.


FTDs are 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 even being proposed as it only hurts the markets integrity.

This rule needs to be cancelled or have a major rework with it leading to actual transparency before it is brought back for consideration.

Chris Tutek.