April 20, 2022
The following is my comment for File Number SR-NSCC-2022-003:
a
The market currently lacks transparency and accountability for large institutions, so the proposal of this rule disappoints me greatly.
This rule would serve only to increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely. In doing so, the deterrent of engaging in what is supposed to be very risky business practice is removed.
It's all upside for market makers that excessively naked short securities, and all downside for those on the wrong side of their naked shorting. How does this rule contribute to a \"fair\" market by any means?
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.\"
It is very frustrating to see rules being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations.