Subject: Rules SR-NCSS-2022-801 and SR-NCSS-2022-003
From: Komninos Tsakkiris
Affiliation:

Apr. 20, 2022

Dear Sir or Madame  


In the light of the introduction of the above rules  SR-NCSS-2022-801 and SR-NCSS-2022-003 to be proposed i would like to complain against them. 


Those rules are creating LESS transparency on an era we vowed to make everything transparent and create fair markets. 


The mentioned rules help FTDs and Naked Short Positions not only not follow up with their obligations but kick them further back with the help of the NSCC acting as intermediary and adding more lending of the securities.  
Prime brokers and market makers that engage in those illegal practices are getting help instead of punishment!  
How are we even proposing something like this to be implemented? 
How are we acting against retail investors who have their portfolio naked shorted? Hurting the value and never covering.  
The system in place already has quite some flaws that hurt investors but help the house on illegal acts as these. And now were helping the house with the crime!  


You have allowed dark pools hurt price discovery. Hurting millions of retail investors every day by trading outside of lit exhanges and in cases allowing only the sale orders in lit exhanges to drive price down while buys go to the dark pools.  


Now we want market makers and prime brokers naked short shares and help as well ? 


Day in and day out retail investors lose faith in the system. 


Please dont let this bad rule to be implemented. It seems a rule tailor made for those who commited illegal acts of naked short selling and failing to deliver to walk away free. 


Regards