Subject: SR-NSCC-2022-003
From: DENNIS W MILLER
Affiliation:

Apr. 20, 2022

 



The following is my comment for File Number SR- 
NSCC-2022-03 
I am writing as a retail investor, very 
concerned about the implications of the rule you 
proposed. 
After going through the file twice, it is very clear 
to me that the rule in fact acts against the interest 
of retail investors, whom SEC is supposed to 
protect. 
It does that by increasing possibility for avoidance 
of true market price discovery through continuous 
lending. It also significantly lessens the infinite 
risk of naked shorting. That practice, as I am sure 
you are aware, is by nature very risky and for a 
good reason. 
Without that risk, the institutional investors are 
free to essentially gamble with taxpayers and 
retail investors money, posing systemic risk to the 
integrity of US stock market. 
What we need is more transparency in how stock 
market works to level the playing field between 
retail and institutions, especially considering the 
widening wealth gap and soaring inflation, among 
other problems our society faces. The proposed 
rule acts in the opposite direction. 
I consider that transparancy essential for a fair 
and sound economy, as well as for 
democracy.Good day