Subject: Regarding SR–NSCC– 2022–801
From: Baraka Gitari
Affiliation:

Apr. 19, 2022

Dear SEC, 


Upon reading the first page of the new proposed rule I found a concerning excerpt. 

"In return for the lent securities, the borrower transfers collateral, and a net rate payment is typically transferred to either the lender or the borrower that reflects the liquidity of the lent securities, as well as interest on any cash collateral" 



Liquidity and market making are often used as euphemisms for back-end deals that result in retailers NOT getting what they paid for. 


It can be this simple. Person pays for a security, person then gets said security after a set number of trading days/hours. NO collateral. NO credit swaps. NO IOUs. The market is needlessly complex and it is becoming more and more clear that this complexity is used to cloak shady and/or criminal behaviour by Hedge Funds, market makers, and custodial banks. 


P.S stop trying to rewrite the same rule over and over again. Take the hint, retail doesn't like it. 


-Baraka -- 


- Penguins can't fly either