Subject: File No. SR-NSCC-2022-801
From: Luke Zaoral

April 20, 2022

This rule obviously suggests a new vehicle, called Securities Financial Transactions, would be created to be used to endlessly prevent FTDs from having any impact on fair market proceedings. The system which measures FTDs, and forces buy ins, is already broken as it does not adequately detect FTDs in many securities, and this would therefore be a step backwards in fair market structure - unless, of course, the participant in question was already abusing market moves - like naked shorting, shorting, married puts, deep out of the money puts, etc - to hide a ridiculous undeliverable position. There are no retail investors on the planet who would think this was a good idea. The already beleaguered US markets look to the rest of the world like a tool to steal the hard earned gains of legitimate American businesses by financial means, and their reputation is suffering immensely. The cost of this rule would be divestment in American markets completely, and usher in more collapse pressure on an already fragile market.