Apr. 20, 2022
Good day, The following is my comment for File Number SR-NSCC-2022-003: The market already lacks transparency and accountability for large financial institutions, and this proposal would further add a layer of protection to those engaged in risky and potentially illegal activities. This proposal would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of “naked” shorting entirely, and in doing so, the deterrent of engaging in what is supposed to be very risky business practice. This proposal allows market makers and others who excessively naked short securities to slither out of their obligations and punishes not only the companies who are driven into the ground by naked shorting practices, but the retail traders holding the legitimate stock. This proposal adds further unfairness and opacity to an already unfair and opaque market. Fail to Delivers (FTDs) are already "reset" through a variety of methods, such as using derivatives to stop them from reaching the 30-day mark when the security is supposed to be delivered. This proposal has already been abandoned several times, for good reason. There should be some sort of stop-gap that automatically rejects any proposal that seeks to slip under the radar after having been rejected by the public a number of times. I am disappointed that these new ways to kill any remaining good faith in our market system keep appearing despite the public having sounded a resounding “NO” to them several times. In addition, I suggest the SEC adopt the Plain Language Act statutes https://www.plainlanguage.gov/ and immediately reject any and all proposals which fail to meet these standards. The public should not have to wade through pages of lawyer-speak in an attempt to educate themselves on new proposals to our market structure. Sincerely, Donna Slinger