Subject: SR-NSCC-2022-003
From: Robert DeMarco
Affiliation:

Apr. 20, 2022

 


Hi, 


To whom it May Concern: 

I will start off by saying that many retail investors, companies and myself do NOT approve of this newly proposed rule (SR-NSCC-2022-003). After reading this file in its entirety, It is my understanding that this newly proposed rule would allow for FTDs (Failure To Deliver), through the use of SFTs (Security Financial Transations), to continue and worsen. This is an exact rule that we are trying to avoid. It is a rule that will allow market makers to continue to abuse FTDs. This does not in any way benefit investors and could potentially be very harmful.
Please do Not allow SFTs (Security Financial Transactions) proposed in this rule, this will create new FTDs and have current FTDs passed along and never settled. We need the FTDs to be settled, as we know there are many FTDs in the market right now. I can see how it provides stability in the moment, but it also allows for abusive practices where market makers are never accountable for their failings. This is not acceptable and creates an opportunity to harm retail investors and companies within the stock market. It violates our rights for a free and fair market. Please take this proposed rule (SR-NSCC-2022-003) off immediately. 
Sincerely,
Robert DeMarco
Concerned market participant and advocator for true and fair markets