Subject: File No. SR-NSCC-2022-801
From: Robert Alexovich

April 20, 2022

This proposal is unacceptable. The purpose of short selling is to aid in price discovery by ensuring that if a security has faults, they have a way to come to light, and if the security is healthy then the price should continue to rise. By allowing the shuffling and obscuration of borrowed and short positions, true price discovery is not possible as there is no reason to close short positions at an 'inconvenient' time and which will then artificially depress security value. This rule goes against the SEC's stated goal of promoting transparency in the market and allows unethical and illegal practices to be practiced with impunity.