Subject: File No. SR-NSCC-2022-003
From: Geoffrey Witcher
Affiliation: N/A

April 20, 2022

As an individual investor, this proposed rule is in direct conflict with market transparency and fairness. It is clear that the intention of this rule is to allow major financial institutions to avoid failures to deliver (FTD), which ultimately negates the need to locate a share for short selling, thus explicitly condoning the abusive practice of \"naked\" short selling. This proposal serves only to add to the already unnecessary market complexity, and is an example of rules designed to create and leverage institutional advantages over individual investors like myself. I oppose this rule and ask that it be dismissed with prejudice.