Subject: File No. SR-NSCC-2022-801
From: Aaron Merickel

April 20, 2022

This rule should NOT pass. It appears it is intended to avoid short seller's current obligations to actually deliver the stock back to those that lent it to them, allowing these FTDs to pile up and be essentially added to yet another list whose sole intent is to avoid EVER settling bad bets made by short sellers.

This 'novation' seems no less than ANOTHER attempt by short sellers and powerful hedge funds to avoid ever realizing losses incurred by their likely illegal naked short selling practices currently under investigation by the Department of Justice.

It is NOT friendly to retail investors, does NOT advance the interests of a free and fair market, and will NOT contribute in the slightest to the transparency and price discovery that's vital to a functioning marketplace for ALL investors.

Similar proposed rules have been introduced TWICE and withdrawn TWICE because they are so incredibly unfair to retail investors. This proposed rule should join them and be WITHDRAWN immediately, and similar rules that intend to further tilt the market in favor of market manipulators and financial criminals forever banned from reconsideration.