Apr. 20, 2022
The following is my comment for File Number SR-NSCC-2022-003: This proposed rule completely undermines legitimate price discovery through onward lending. This proposed rule also decreases transparency and seems to intentionally benefit market makers at extreme cost and unfairness to other market participants. It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. Instead of continuing to propose rules that functionally INCREASE the number of available methods to manipulate FTDs legally albeit unethically, the SEC should be ashamed to propose anything that doesn't actively reduce loopholes like this. I would ask that you vote NO on SR-NSCC-2022-003 and by doing so, enforce the concepts of free and fair markets for ALL participants, not just market makers. Respectfully submitted with a great desire for change, Ryan