Apr. 20, 2022
To whom it may concern, The proposed rule SR-NSCC-2022-003 is not beneficial to our financial markets in any way whatsoever. This rule only furthers the complexity and lack of transparency in our markets and further allows large participants to commit fraud. This rule is exactly like check kiting, an illegal practice. What is check kiting you might ask? So if you wrote a bad check to yourself for $10,000 and went and cashed it...the bank would give you the cash, but that check would then bounce in a few days and you would owe $10,000 plus bounced check fees. But, if you had another account, and wrote a new check for $10,000 you could cover the obligation on the first account. But then you have to use another account to do the same again and again. You have $10,000 cash and you have an obligation for $10,000 but you just delay it coming due. If you can delay it indefinitely, you just got $10,000 for nothing. It's called check kiting and it's illegal and you will be caught and go to jail. This is what this rule essentially allows but with borrowed shares that never have to be covered. Please DO NOT pass SR-NSCC-2022-003. This only harms our financial systems even further! Please do the right thing, Garrett Godfrey