Subject: SR-NSCC-2022-003 & SR-NSCC-2022-801 Comments from a concerned retail investor
From: Cameron Lacy
Affiliation:

Apr. 20, 2022



To Whom It May Concern:

As a retail investor I am highly disturbed by the content of this new
proposed rule that would effectively allow for Failure To Delivers
(FTDs) to continue and worsen, which can be abused by market makers
and used in conjunction with naked shorting and dark pool trade
routing to control and suppress the price of equities. This does not,
in any way, benefit investors and is likely to be extremely harmful to
the vast majority of investors.

Please do not allow Security Financial Transactions to allow new
methods of negligence, whereby the financial obligations of the FTDs
get passed along instead of settled. This proposed rule is shorted
sighted in its attempt to create stability and allows for abusive
practices where market makers are not held accountable for their
failings. This is not acceptable and creates an opportunity to harm
retail investors and violates our right to a free and fair market. In
order for the equities markets to be fair, market makers must be held
accountable for their financial obligations, regardless of the short
or long term consequences they face.

I request that this proposed rule be denied and that similar rules are
not proposed 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 repeated attempts for such a measure to be
passed after multiple rejections points to the potential desire for
malpractice by market makers.

The mission of the SEC is ensure and protect 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 which is inherently harmful to retail investors
and which unfairly benefits Market Makers and brokers who do not have
investors best interest in mind. Another worthy target for your
attention would be to completely shut down the use of dark pools which
has been used to undermine competition in the equities market and
actively suppresses price discovery. As Head Chairman of the SEC, Gary
Gensler, has stated multiple times, "90-95% of retail order flow does
not reach the lit markets." This is absolutely unacceptable and must
be rectified immediately.

Thank you for your timely attention to this matter, and please honor
your obligations to protect investors from predatory behavior by
financial institutions.

Sincerely,
Cameron Lacy