Subject: SR-NSCC-2022-801
From: Jim Rodgers
Affiliation:

Apr. 20, 2022


These 188 pages describe a convoluted scheme to enable obligations to be sidestepped and is unacceptable! This rule seeks to allow large marketmakers such as Citadel to clear obligations and allow them to continually naked short companies. This new rule cannot stand! 

Look up Citadel's short swap data and see all the companies they are ‘cellar boxing’. Many have already gone bankrupt. Abusive naked short selling (predatory synthetic share counterfeiting) is STEALING. This rule enables the fraud to continue. Please implement rules that protect companies, investors, and fairness. 

Thank you, 
Jim Rodgers