April 20, 2022
As a retail investor I'm very concerned about the nature of these proposed changes. SFTs would act contrary to retail's interest especially in cases of naked shorting of stocks that I and other retail investors may each individually be holding long-term.
SFTs only appear on the surface to provide fair value to the stockholder, in practice it is my belief that SFTs would be used against the interests of individual stockholders to escape practices of naked shorting by hedge funds and market makers.
I understand that my terminology as an unsophisticated retail investor may not match perfectly with the legal wording of the proposed rules, however I hope that the spirit of my comment is clearly conveyed - if an institution or individual shorts a stock and fails to deliver, they should be forced to buy-in directly at market price (without substitutions or SFTs) as that is the nature of the investment they have chosen to make. As a country and SEC institution we should not attempt to limit their risk, instead they should be forced to face the consequences of their reckless and destructive investing strategies.
Thank you for your time, please note my comment is strongly against SR-NSCC-2022-801.