April 25, 2022
I am writing to you to voice my opposition to the proposed rule SR-NSCC-2022-801. This proposed rule would negatively impact markets in many ways including increasing systemic risk , decreasing transparency, and allowing short positions and failures to deliver to persist indefinitely in violation of REGSHO as well as the Dodd-Frank Act.
Creating more complexity in securities lending will cause great harm to retail investors who are already at an unfair advantage in markets. US markets suffer from an unreasonable lack of price discovery caused by the predatory actions of the very financial institutions pushing this terrible rule. Markets need more transparency around securities lending, not less. Further, the proposed rule will preemptively circumvent the SEC's proposed rules regarding the tracking of loaned securities.
I urge the SEC to reject this proposed rule.