Subject: SR-NCSS-2022-003
From: Alexander Budd
Affiliation:

Apr. 20, 2022

 


Good Afternoon: 


I am a fairly new retail investor and disturbed by the content of the above-referenced proposed rule. As a fairly new investor, I frankly don't have a full understanding of all the intricacies of the stock market, despite my best efforts. I think the complexity of the market is unfortunate but intended - and this rule plays into that problem, clocking in at 188 pages with serious consequences to retail investors. 


As I understand it, the contents of this proposed rule have been rejected previously. "NSCC understands that SFTs provide liquidity to markets and facilitates the ability of market participants to make delivery on short-sales, and thereby avoid failures to deliver, “naked” shorts, and similar situations." I would suggest that there are better ways to avoid "failures to deliver, "naked" shorts, and similar situations" than to allow those entities engaging in such practices to further abuse the markets through another layer of endless can-kicking of their obligations by way of swaps (by another name). 


Thank you for your time and attention to this matter. 


Sincerely, 
Sandy Budd