Apr. 19, 2022
To whom it may concern, I am writing today to strongly urge against the passing of SR–NSCC–2022–801. The NSCC does not need more inventive ways to paper over failures to deliver. This rule is an absolute abomination and does nothing to protect retail investors from Wall Street's addiction to selling securities they don't own. I'm sure the largest members of the DTCC are all in favor of being able to borrow, lend, re-lend, and re-borrow shares ad-infinitum as it enables them to continue to grift hard earned cash from retail traders, pension funds, and 401ks. I'd venture a guess most high frequency trading firms are also in favor of the continued flow of "liquidity" that enables them to offer fake "price improvement" by front running trades. If you want to do something useful for once, consider ending failures to deliver by enforcing a hard locate provision for short sales, and timely settlement. In the meantime, dump this rule in the garbage bin next to Gary's desk. Thank you, Andrew Harmon