Subject: Comments re: SR-NSCC-2022-801
From: Paul Sherman
Affiliation:

Apr. 20, 2022



To Whom It May Concern:

As a retail investor I am greatly concerned by the content of the new proposed rule SR-NSCC-2022-801. If adopted, this rule would allow for FTDs (Failure To Deliver) to continue and worsen. FTD's can be abused by market makers. They use FTD's in conjunction with illegal naked shorting and abusive dark pool trade routing to control and suppress the price of certain securities. This does not in any way benefit investors and in fact could be extremely harmful.

Please remove this proposed rule and furthermore please do not try to propose something similar again in the future, as iterations of this have been rejected in the past and continue to be rejected by educated investors every time they resurface.

The mission of the SEC is to look out for the well-being of investors such as myself, so I would propose that you direct your attention to doing so. This would best be accomplished by banning Payment For Order Flow. PFOF is inherently harmful to retail investors and  benefits market makers and brokers who do not have investors' best interests in mind.

A more worthy target for your attention would be to shut down the abusive use of dark pools by market makers such as Citadel, which they use to undermine the true value of securities traded by retail investors and to suppress price discovery.

Thank you in advance for your timely attention to this matter, and please live up to your obligations and help the investors from predatory behavior by financial institutions.


Best Regards,
Paul Sherman


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Paul J. Sherman