Subject: SR-NSCC-2022-801
From: Marc Elmer
Affiliation:

Apr. 20, 2022

 


It's extremely disheartening that retail investors have to once again try to defend ourselves against the larger, more well-funded market makers that control the stock market. The current market simply lacks transparency and accountability for large institutions. As a retail investor, I'm disappointed and extremely concerned that SR-NSCC-2022-801 has been proposed, and I am staunchly against it.


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 when the deck is ALREADY stacked in thier favor, and has been for years. They excessively naked short securities, and all create infinite downside for those on the wrong side of their shorting.


How in the world does this rule contribute to a "fair" market?


It's absolutely ridiculous. 



FTDs can already be "reset" through various methods such as using derivatives, not allowing them to reach their 30-day mark where the security needs to be "delivered."
It's maddening to see rules like this one being proposed, as they only favor reckless institutions, and lead to more damage and obfuscation in our market. Hopefully, the SEC will consider the words of retail investors on present and future regulations, as retail investors continue to labor against huge disadvantages throughout the investment world.


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-2022-801proposal. Please. For us, for the little guy who doesn't have the funding or the power that these massive institutions have.


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,


Kevin Carmichael