Subject: SR-NSCC-2022-003
From: Ed Dodge
Affiliation:

Apr. 20, 2022



To whom it may concern,

The market already lacks transparency and
accountability for large institutions, so im
disappointed this rule is being proposed.
I've read every single page of legal speak in the file
and it is very clear what this rule proposes.
This rule would increase avoidance of true market
price discovery through onward lending. It also
removes the infinite risk of naked shorting entirely,
and in so doing the deterrent of engaging in what
is supposed to be very risky business practice.
It's all upside for market makers which excessively
naked short securities, and all downside for those
on the wrong side of their shorting. How does this
rule contribute to a "fair" market by any means...
?
I don't see it.
FTDs are already "reset" through a variety of
methods such as using derivatives not allowing
them to reach their 30 day mark where the
security needs to be "delivered."
This is very frustrating to see rules like this being
proposed that only favor reckless institutions.
Hopefully you'll consider the words of retail
investors more with your decision making on
regulations, as we've been educating ourselves a
lot more over the past couple years.

Respectfully,

Ed Dodge
315-945-9798






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