Subject: File No. SR-NSCC-2022-801
From: Matthew Banks

April 26, 2022

This rule is a clear attempt to launder illegal naked shorts and FTDs.This rule seems to want to allow many bad actors and the like who have made bad bets to continue kicking the can and create another layer of lending and creation of shares that should not exist. There are already so many frayed tactics used that makes the market so difficult for a retail investor. I.e, (short exempt, naked shorting, ladder attacks, recycling of FTDs, max pain pinning of stocks, creating synthetic shares, dark pool abuse, OTC market abuse). This will put a greater strain on the market in the long run. The DTCC and the NSCC both know there are billions upon billions of dollars worth of Naked Shorts, FTDs and the like that need cleared. This rule is written to circumvent that requirement and allow these funds and institutions a way out of clearing these shorts and FTDs. Brokers, hedge funds and the like have acquired debts they do not want to pay, or might not even be capable of paying. A perfect example is Citadel owing (per their 2021 statement) over $65 billion in securities sold, not yet purchased, at fair value. So, rather than pay their debts like the rest of us, they make new rules to avoid them. In the process this will be the largest robbery of assets in world history, as well as the blatant rigging of a market that is suppose to be fair. This rule allows hundreds of billions of dollars to go unpaid while harming retail investors, retirement funds, mutual funds, and others.This is a clear example of powerful funds and institutions making rules because they made bad investments and want us to pay for it. If any average middle class/ retail trader attempted a move like this, it would be considered money laundering and I would be charged with a felony offense. Yet, many dont have the power to simply change the rules to benefit self. The passage of this proposal would give hedge funds, brokers, banks, and many others an even greater advantage over retail while further suppressing market transparency. The state of our stock market can not survive like this. We need market transparency. We need a free, fair, and open market.