Subject: SR-NSCC-2022-003
From: Doug James
Affiliation:

Apr. 20, 2022


This rule would increase avoidance of true market price discovery through onward lending. 

It also removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice.
It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. 

How does this rule contribute to a "fair" market by any means? I don't see it.

FTDs are already "reset" through a variety of methods, such as using derivatives that don’t allow them to reach their 30-day mark where the security needs to be "delivered."

It is very frustrating as a retail investor to see rules like this being proposed that only favor reckless institutions. 

Hopefully you'll consider the words of retail investors more with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years.

I vote no on this proposal.

Doug James
 
Scott Depot, WV





Sent from Mail for Windows