Subject: SR-NSCC- 2022-801
From: Stephen Millsap
Affiliation:

Apr. 19, 2022

Dearest Commission,
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DO NOT implement this rule. The idea that problems caused by naked shorting, securities lending and failures-to-deliver should be addressed by slapping on a band-aid that essentially consists of more securities lending is absurd. This commission should be implementing rules that make markets simpler and more transparent. This rule would seemingly cause the opposite with further obfuscation of the internal plumbing of the market. When systems like the stock market are over complicated, bad actors have significantly more loopholes and shady corners to take advantage of that complexity. That is exactly what the rule will be used for, allowing large financial institutions to shrug off obligations as if they do not exist. Do the right thing.
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Best,
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Stephen Millsap 

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