Apr. 20, 2022
Hello: These rules have been proposed and withdrawn twice already; this is now the third time they've been introduced- stop it already! I am a retail investor. SR-NSCC-2022-801 and SR-NSCC-2021-003 exist only to avoid market price discovery through onward lending. It removes the infinite risk of naked shorting entirely, removing any deterrent from those who wish to engage in such risky and illegal behavior. This is wrong, a thousand times wrong! In short, SR-NSCC-2022-801 and SR-NSCC-2021-003 help criminals manipulate the markets, while punishing those who are on the wrong side of their shorts. These rules are not in line with a fair market system. In fact, they give bad actors yet another venue for cheating the system- a venue that retail investors have no access to. SR-NSCC-2022-801 and SR-NSCC-2021-003 don't alleviate fail-to-delivers as implied; all they do is protect naked short selling. It's essentially a license to cheat: "Okay guys, get ready to naked short some stock. If we can't locate what we need, instead of failing-to-deliver, we'll create temporary IOUs, and when the time comes, if we can't locate again we'll create more IOUs to replace the original IOUs, and keep getting away with our scam." Stop aiding and abetting criminal behavior. Kill SR-NSCC-2022-801 and SR-NSCC-2021-003 permanently. Looking forward! Chris