Subject: SR-NSCC-2022-801
From: Evan Milowic
Affiliation:

Apr. 20, 2022

 



SEC, 


The proposed rule SR-NSCC-2022-801 should NOT be passed. 

It would allow exponentially increased share lending without accountability for bad actors making poor choices and putting everyone else at risk. 



This rule effectively creates a darkpool for the short party during a short squeeze or forced share buyback (dividend, recall, etc.). 


If enacted, this rule would actively incentivize fraudulent market behavior by opening up a loophole in which covering Failed To Deliver Shares would no longer be reflected in the price of a security. The changes in this proposal can and will be abused by bad actors in an effort to further negate accurate price discovery, to the great detriment of all retail investors. 



This rule MUST NOT PASS. 


-Evan Milowic