Subject:
From: Robert Crabill
Affiliation:

Apr. 08, 2021



I believe this will be a beneficial rule update for the market as a whole. As is seen in the submitted documents there doesn't appear to be a downside for Participants/Members as the SLD will be returned to them more quickly. Additionally, it will help ensure that all players from retail to Market Makers are on a more even footing. The delayed submissions of information such as short interest, Failure to Delivers, and up to date information available for all players puts the majority of the market at a major disadvantage as when the information is released to the public it is weeks old thus eliminating any advantage that retail investors could have used to get a stronger position in the market. Unfortunately with the current interpretation of rule 4(a), large market players have information well in advance of everyone else, thus giving them an unfair advantage in what is supposed to be a fully open market. 

With the implementation of SR-NSCC-2021-801, it will give the NSCC/DTCC the ability to interfere in the going on of the market so that everyone can have an even footing and hopefully allow retail investors the ability to trust the market more since the Clearinghouse will have the ability to better enforce actions of members so that the stability of the market is not put into jeopardy by high risk plays.