Subject: File No. SR-NSCC-2022-003
From: Gregory Bergen
Affiliation: ISSM

April 20, 2022

This rule is just a Market Maker's \"infinite share loophole,\" an Overnight Reverse Repo, and a dark pool internalizer all-in-one

The prime brokers, the hedge funds, and the market makers will be able to simply request an SFT 'loan' on a share that doesn't exist, anytime they want.

In return, they're suggesting that the SFT be paid for by posting \"cash collateral equal to the market price of that security.\" THIS IS JUST A MARKET ORDER BY A DIFFERENT NAME It's a completely off-exchange, re-routed buy order from an NSCC-sponsored dark pool with an infinite supply It doesn't matter if it's \"overnight\" or temporary. It's creating liquidity from shares that do not exist