Apr. 20, 2022
This rule being proposed is a distortion of the "fair and efficient" markets the SEC claim to uphold. The market already lacks transparency and accountability for large financial institutions and so it is incredibly dissapointing that this rule is being proposed. The NSCC would have you endorse the their criminal activities under the supposed illusion of "fairness" This rule would increase avoidance of true market price discovery through onward lending. It completely removes any risks associated with shorting and naked shorting entirely and thus allowing institutions to engage in an incredibly risky business practice with no appreciable downside. This policy has been proposed twice before under different guises to ensure that there are no consequences for their actions. It is all upside for market makers who excessively short securities, and all downside for those on the wrong side of their shorting. This rule does not contribute to a "fair" market. Failures to deliver are already allowed to be resent through the use of complex derivatives methods, ensuring they never meet the 30 day threshold where the securities need to be delivered. This rule is a demand by the NSCC for the SEC to abandon your mandate to protect investors and maintain fair, orderly and efficient markets. The SEC mandate is not liquidity at any/all costs and orderly markets reuiqre stringent and transparent rules on borrowing and price discovery, which is what this submission would effectively limit. As someone who works in the financial industry I urge you to do away with this bill so that the US financial markets continue to be the premium destination for investors worldwide. Kind regards, David Groogan