Subject: SR-NSCC-2022-801
From: Joshua Karchie
Affiliation:

Apr. 20, 2022



The current market lacks transparency and accountability for large
institutions. As a retail investor, I'm disappointed and extremely
concerned that SR-NSCC-2022-801 is being proposed.

This rule would increase avoidance of true market price discovery
through onward lending. It also removes the infinite risk of naked
shorting entirely and in so doing, the deterrent of engaging in what
is supposed to be an unsafe and harmful business practice.

This new proposal would become an outrageously unfair advantage for
market makers, which excessively naked shorts securities, and all
create infinite downside for those on the wrong side of their
shorting.

How does this rule contribute to a "fair" market by any means...?

I don't see it.

FTDs are already "reset" through various methods such as using
derivatives, not allowing them to reach their 30-day mark where the
security needs to be "delivered."

This is very frustrating to see rules like SR-NSCC-2022-801 being
proposed, as they only favor reckless institutions. Hopefully, the SEC
will consider the words of retail investors on present and future
regulations, as retail investors continue to get the "short end of the
stick" throughout the investment world.

I firmly believe SR-NSCC-2022-801 is an insult to anyone and everyone
who has ever purchased a security in our markets. Through this new
proposal, the NSCC would have you endorse their criminal activities
under the illusion of fairness.

This same policy has been proposed TWICE before under different guises
and has previously been "shot down" or revoked. Large financial
institutions are horrified that they might no longer have the option
of taking risky bets and not facing the financial or legal
consequences.

It sickens me to see market makers and financial institutions propose
such blatant exploitative methods repeatedly, just waiting for the day
one of their biased and unfair proposals slips through. They think
they are above the law, the consequences, and the investors they
exploit.

I would firmly ask that you deny the SR-NSCC-2022-801 proposal.

As a retail investor, I implore you to take this threat to the very
sanctity, fairness and transparency of our markets for what it is - a
threat against every single retail investor.

Please do your part and stop this.

Signed,