Subject: File No. SR-NSCC-2022-003
From: Rowland

April 20, 2022

Fair and orderly markets need more locates and less borrowing.

This rule is a step backwards.

NSCC understands that SFTs provide liquidity to markets and facilitates the ability of market participants to make delivery on short-sales, and thereby avoid failures to deliver, naked shorts, and similar situations.

NSCC would use its risk management resources to provide confidence to market participants that they will receive back theircash or securities, as applicable, which should limit the propensity for market participants to seek to unwind their transactions in a stressed market scenario.