April 20, 2022
The market already lacks transparency and accountability for large institutions, so I am very disappointed that this rule is being proposed.
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 (who already 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? From a retail perspective, it does the opposite.
FTDs (Failed To Delivers) 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.\"
Please do not allow this proposal to become a rule. It is very frustrating and disappointing to see rules like this being proposed that only favor reckless institutions instead of retail. Hopefully you'll consider the words of retail investors more with your decision making on regulations such as this one.