Apr. 22, 2022
Dear ladies and gentlemen, The following is my comment for File Number SR-NSCC-2022-03 I am writing as an overseas retail investor, very concerned about the implications of the rule you proposed. It reads to me the rule in essence 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 share 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 and how prices are found. a value of a Company is defined by bid and ask of real shares, not by artifical shares created out of thin air in order to drop share prices so that cost to borrow can be controlled by the dominant players. a Fair market allows to level the playing field between retail and institutions, especially considering the widening wealth gap and soaring inflation, among other problems our society faces. As far as it is writen in your legislations, the portection of those key market metrics is the responsibility of the SEC - and you are failing miserably! The proposed rule acts in the opposite direction. I consider supposed but non-existent transparency essential for a fair and sound economy, as well as for the democracy. Having said all that, I sincerely hope that whoever this concerns, will reevaluate their position and withdraw that ruling completely. I can only hope that they also think about the normal mortal small investors and not only about the big ones who leave us no air to survive and do with us what they want. Sincerely,