Subject: SR–NSCC– 2022–801
From: Anonymous
Affiliation:

Apr. 19, 2022

Hello,

I oppose the passing of this rule. This proposal is not in the interest of retail investors. This does not lead to transparency. Bad actors can just borrow the shares they need anytime they want, whether they're available to borrow or not, and they can base the collateral requirements off of the INITIAL PRICE OF THE STOCK THEY NEEDED TO BORROW, then "close out their positions" so someone else has to hold the bag. It's a means of kicking the can, once every 24hrs while avoiding ever paying top-dollar for poor decisions.

Brokers would be given the freedom to "lend" SFTs created by the NSCC whenever, and charge whatever they want. If they want to charge each other zero dollars to lend those imaginary shares, they can.

Serve the common investor and withdraw this rule proposal.

-S.P.