Subject: File No. SR-NSCC-2021-801
From: Zachary Downs
Affiliation: Retail Investor

April 9, 2021

It has become clear to the retail investor community that hedge funds and money managers operate on a different playing field. Borrowing shares on leveraged capital to short a stock is extremely risky. Worse than that, naked short selling is taking place every day in the market on a grand scale. Failure to delivers are rapidly rising as a result. This puts the entire market, including my own portfolio, at risk. Reform is necessary and the implementation of this rule is a step in the right direction. Thank you for your time and consideration.

Best Regards,

Z Downs