April 21, 2022
RE: SR-NSCC-2022-801
I cannot believe we are actually debating whether this proposed rule will in fact be adopted as a rule. Market makers, hedge funds, institutional investors already have significantly more advantages versus the average retail investor. While we've seen the abuses of dark pool (ATS) trading strategies such as diverting sell pressure of a stock to the \"lit\" exchanges to prevent price discovery, the buy pressures on individual stocks have been withheld and internalized into dark pools, never seeing the light of day or even given the opportunity to allow for price discovery.
Failure to delivers? Who has ever heard of such a thing? Will retail traders be granted the same privileges? Non-delivery is unacceptable and deliveries have to occur on \"lit\" exchanges to allow for price discovery.
Allowing SFTs will not only absolve Wall Street of their high-risk and reckless behavior, but it further encourages more risk-taking. SFTs will allow for a \"back stop\" for short sellers. Short selling is inherently risky and should be dissuaded if anything, not rewarded. Wall Street already has multiple financial instruments for \"resetting\" FTDs via derivatives, ex clearing, etc and it does NOT need another loophole in which to evade its own financial obligations.
Short sellers and derivative traders often know, that these practices carry infinite risk which compounds exponentially with leverage.
Please don't penalize retail investors for simply being the counterparty to Wall Street's reckless and potentially fraudulent behavior.
Sincerely,
J. Cox