Apr. 21, 2022
To whom it may concern, This email is in regards to my concern over the proposed SR-NSCC-2022-003 rule. This rule needs to be withdrawn because it does not protect the retail investor and allows failures to deliver (FTDs) caused by short selling to be hidden and consolidated. This rule thus creates an unfair advantage for the large hedge funds and institutions. As a quick example please look at the word count of some terms from the 47-page document: 'sponsoring member' (563x) 'sponsored member' (456x) 'default' (176x) 'risk' (115x) 'institutional' (59x) 'securities lending' (16x) 'liquidity risk' (13x) 'credit risk' (12x) 'systemic risk' (5x) 'squeeze' (1x) 'transparent/transparency' (No matches found) 'retail' (No matches found) 'fair' (No matches found) Note the 1,019 occurrences of the words' sponsoring/sponsored member' with no mention of words like transparent, fair, or retail. This rule leverages the complexity of financial vehicles to put power in the hands of institutions, effectively safe-guarding them from their own bad bets. Passing this new rule would only deteriorate the American public's faith in a "free and fair market". I urge you to withdraw this proposal immediately. Thanks, Oliver A Retail Investor