Subject: File No. SR-NSCC-2022-801
From: James A

April 20, 2022

This is essentially the \"overnight reverse repo\" program, but for Failure To Delivers or FTDs. They can just borrow the shares they need anytime they want, whether they're available to borrow or not, and they can base the collateral requirements off of the INITIAL PRICE OF THE STOCK THEY NEEDED TO BORROW and \"close out their positions\" so someone else has to incur loss. It's essentially kicking the can, once every 24hrs. And they can avoid ever paying top-dollar during volatile market conditions.

Brokers would be given the freedom to \"lend\" SFTs created by the NSCC whenever, and charge whatever they want.

They're taking the \"infinite share copy machine\" that the market makers have \"for the sake of liquidity\" and making it common practice.

I am STRONGLY AGAINST this proposal as we are aware of the abuse that occurs in the overnight lending market between facilities that govern their own transactions.

A resounding NO to this rule or any other rule promoting overnight lending at discounted rates to avoid obligations