Subject: SR-NSCC-2022-003
From: Jonathan Cruce
Affiliation:

Apr. 20, 2022



As a retail investor I am highly disturbed by the content of this new
proposed rule that would effectively allow for Failure To Delivers
(FTDs) to continue and worsen, which can be abused by market makers
and used in conjunction with naked shorting and dark pool trade
routing to control and suppress the price of equities. This does not,
in any way, benefit investors and is likely to be extremely harmful to
the vast majority of investors.

Please do not allow Security Financial Transactions to allow new
methods of negligence, whereby the financial obligations of the FTDs
get passed along instead of settled. This proposed rule is
short-sighted in its attempt to create stability and allows for
abusive practices where market makers are not held accountable for
their failings. This is not acceptable and creates an opportunity to
harm retail investors and violates our right to a free and fair
market. In order for the equities markets to be fair, market makers
must be held accountable for their financial obligations, regardless
of the short or long term consequences they face.

I request that this proposed rule be denied and that similar rules are
not proposed in the future, as iterations of this have been rejected
in the past and continue to be rejected by educated investors every
time they resurface. The repeated attempts for such a measure to be
passed after multiple rejections points to the potential desire for
malpractice by market makers.  The goal of new rules should be to
foster more transparency in the market, not less.

Thank you for your timely attention to this matter.