Apr. 20, 2022
he current market lacks transparency and accountability for large institutions. As a retail investor, I'm disappointed and extremely concerned that SR-NSCC-2022-801 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 unsafe and harmful business practices. This new proposal would become an outrageously unfair advantage for market makers, which excessively nakedly short securities, and create infinite downside for the counterparties which lend them the shares through failures to deliver of borrowed stock. Failures to deliver are already used as a method to skirt obligations to return borrowed stock. With the use of derivatives such as options, borrowers can extend their borrow period and continue to fail to deliver. It is very frustrating to see rules like SR-NSCC-2022-801 being proposed time and time again. It clearly favors the reckless actions taken by institutions and their counterparties. As a retail investor, I firmly believe that the SR-NSCC-2022-801 proposal will not contribute to a fair and free market, but quite the contrary. I strongly urge you to reconsider the approval of this proposal and deny it based on the issues stated in this comment. Respectfully, P.S. Hopefully, the SEC will consider the words of retail investors on present and future regulations. Thank you for your service, Subhra