Apr. 20, 2022
I am writing in response to the proposed rule SR-NSCC-2022-003. The current market lacks transparency and accountability for large institutions. As a retail investor, I am disappointed and extremely concerned that SR-NSCC-2022-003 is being proposed. This rule would increase avoidance of true market price discovery through onward lending. It completely removes the infinite risk associated with short selling. As a result, the deterrent of engaging in the harmful and unsafe business practice of predatory and naked short selling no longer exists. This new proposal would effectively become an outrageously unfair advantage for market makers, which excessively naked short securities, creating ever increasing downside for investors on the opposite side of this shorting. Failures to deliver are already “reset” through various methods, such as the ambiguity of the derivatives market, before reaching their 30- day delivery due date. This has allowed FTD’s to be rolled over continuously, in many securities, for years at a time with virtually no consequence. As a retail investor, it is infuriating to see rules such as SR-NSCC-2022-003 being proposed, as they clearly favor large, reckless institutions. I believe SR-NSCC-2022-003 is an insult to anyone who has ever purchased a security in our markets. Through this new proposal, the NSCC would have you, the SEC, endorse and embrace their criminal activities under the guise of fairness. It is becoming increasingly evident that naked short selling is being used on a massive scale by major financial institutions to siphon wealth out of companies and away from investors. It is sickening to see the blatant exploitation and disregard for markets and investors that these proposals repeatedly demonstrate. I firmly request that the SEC deny the SR-NACC-2022-003 proposal, and all future proposals that add layers of ambiguity and unnecessary complexity to our markets. I implore the SEC to more readily consider the words of retail investors on present, and future regulations in regards to true market transparency and accountability. Signed, Braxton Fullmer