Subject: File No. S7-08-22
From: Andrew Cross
Affiliation: Company Director

March 31, 2022

Thank you for the opportunity to comment.

I am a uk resident who has invested in the nyse stock exchange.

I think you have a market structure problem, that more people are becoming aware of and I think this rule will go some way to restoring confidence in the market.

Market makers, should not be able to create short shares without where they have been borrowed from being accounted for otherwise the same share may be lent out multipul times leading to dilution of the stock and adversely affecting the share price and value.

Block chain technology would be a great way to track share lending and punitive fines for rule infringement should be implemented to deter preditory shorting by Market Makers, Family Offices and Hedge Funds.

An issue to consider from the SEC perspective is the inherent risk of a market collapse caused by the unregulated and unsupervised creation of synthetic shares.

The systemic risk could be catastrophic.

Thanks again for the opportunity to comment.