December 3, 2021
I am against the rule change based on the following terms.
\"In a case of an SFT Member default, NSCC would be able to delay its satisfaction
of final settlement obligations to non-defaulting SFT Members beyond the normal
settlement cycle for the purchase or sale of securities to the extent NSCC determines that
taking market action to close-out some or all of the defaulted SFT Members novated SFT Positions would create a disorderly market in the relevant SFT Securities. In such a
situation, non-defaulting SFT Members would not be able to effect a recall or an
associated buy-in or accelerate the delayed final settlement obligations. During any such
delay, NSCC would continue paying to and receiving from non-defaulting SFT Members
the payment for the change in market value of the securities with respect to their novated\"
Introducing delays in systems creates less stability as signals and thus data take longer to register by the system. As well, the language used is too generalized and leaves too much room for interpretation. With no set time frames stated there is no definite time period for firms to pay what they owe.
To allow this to go through as is will further damage our financial market.