Subject: File No. SR-NSCC-2021-010
From: J K Rogers
Affiliation: Market Analysis Consultant, Systems Design Engineer, MN/VT Missouri

February 13, 2022

This will be a concise, to the point comment AGAINST the proposed rule change. This proposed change is overwhelmingly further enabling market securities fraud and abusive short-selling practices.

As acknowledged in the rule language itself, it is no secret that illegal short selling- i.e. \"naked\" short selling- exists, is widely accepted but not publicly acknowledged, and rule changes like this continue to protect bad acting market makers and the like. Hiding these actions in the name of 'liquidity' is abusive in and of itself- there may have been a point in the market's history where providing liquidity in this manner was beneficial, but that ship has long sailed, and this practice unfairly hurts the retail investor, and at its worst, can ruin smaller funds, companies, and individual investors outright.

To put it simply- this proposed rule change is bad faith market actors circling their wagons around what has effectively become their private casino, and allows swapping of longs back and forth for cash to avoid margin call failures.

These potential 'defaulters' have knowingly participated in illegal market activity, further enabled by complicit market makers, and are attempting to avoid full accountability after enjoying unfathomably large returns on these positions for years and years.

If an individual were to perform actions like this with tangible real-world assets (cars, homes, etc.), they would be in jail the instant they 'failed to deliver'.

The SEC needs to deny this rule change, and start taking major action on behalf of retail investors nationwide. There are millions of people, if not hundreds of millions that will now never trust the stock market and investing in securities because of the actions brought to light in the past few years, and the wholly inadequate response by the SEC of any kind of meaningful enforcement. Fines as a punishment simply are a cost of doing business if you're making 100x what that fine is annually. Why would you stop? If you convince enough people high up the chain that you're \"too big to fail\", you'll just get bailed out on US taxpayer's coffers in the end. So this continues to happen.

Please. Please expose these illegal actions, and enforce actual consequences for treating retail investors like idiots, skimming money away from hard working people everyday, and ultimately getting bailed out with OUR MONEY when it inevitably blows up in everyone's faces when it could've been prevented to begin with.

Thank you.