Apr. 20, 2022
To whom it may concern, This proposed rule doesn't protect retail investors or the American taxpayer - it appears to do the opposite. This proposed rule is another layer of complexity on an already complex system. It will be used by bad actors to further obfuscate the market's Failure To Deliver problem with short selling and will effectively take away the risk and incentives to bet against the American people and economy. Irresponsible hedge funds and market makers do not need more devices to side-step risk - there needs to be a renewed focus on accountability and enforcement of existing regulations. Masking our market's FTD issue with new Security Financial Transaction vehicles and clearing houses will only exacerbate our market issues. Allowing onward lending of shorted shares amongst bad actors to avoid real price discovery is not going to solve the underlying problem with FTD - it's the "failing to deliver" part that needs swift attention. SR-NSCC-2022-801 will hurt investors. It will hurt market credibility and trust. And ultimately, it will weaken our national security. Sincerely, Matt Castle Concerned Citizen and Investor