Subject: SR-NSCC-2023-003, SR-FICC-2023-004, SR-DTC-2023-003
From: Cam Anderson
Affiliation:

Apr. 14, 2023

How am I supposed to comment on these rules if large swaths of information is redacted. That is the opposite of transparent and seems to me only serves those who know how it really works and the people in their circle who they tell. The "free and fair markets" are so far from that it's an oxymoron at this point. 


Regarding the third party pricing vendors, I don't see how essentially adding more ratings agencies (just like the CMBS market) helps at all. These ratings agencies have inherent conflicts of interest built into the business model, if their biggest clients can influence ratings of their securities simply by threatening to move their business to another agency the whole system is a farce. There needs to be some reason to guarantee accuracy and legitimacy of information built into the business model. I am not sure on specifics for such a system but in my opinion introducing these agencies without that simply creates another source for corruption.