Subject: File No. SR-NSCC-2021-010
From: R Davidson
Affiliation: Research Scientist

November 28, 2021

It is entirely fraudulent to allow insiders to form a group where they are not liquidated in the event of a default and that provides the group members the ability to post collateral or purchase the securities from the defaulting member in order to \"not disturb the market\". The guise of preventing volatility directly defrauds the retail investor of being able to invest or play the volatility themselves. Internalization of volatility AND defaulting/liquidation activities is INSIDER TRADING and robs retail the right to participate in said events.Furthermore, preventing a member from going through default or liquidation because of a short position taken out on their own accord, robs long positions of their rightful returns. Instead shielding a defaulting member using other insiders.

This rule sets up a private group of insider market makers etc to protect each defaults and so they never have to face the music like a retail individual. This is taking insider trading and fraud to the next level. This IS FINANCIAL TREASON.