Apr. 20, 2022
Hi there, The following is my comment for File Number SR-NSCC-2022-003: I'm disappointed this rule is being proposed; the market already lacks transparency and accountability for large institutions. After reading every single page of legal speak in the file, I have come to a clear conclusion. 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. I don’t see how this rule contributes to a "fair" market by any means. FTDs are already "reset" through a variety of methods such as using derivatives, which doesn’t allow them to reach their 30 day mark where the security needs to be "delivered." It is very frustrating 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. Thank you for your time, Dawn Dehdari-Dris