Subject: File No. SR-NSCC-2022-003
From: Lubomir Gula

April 19, 2022

The SFT service is completely voluntary and NSCC members are being essentially enticed to participate in it. The SFT novates all old obligations into new ones so whatever rules and regulations that pertain to whatever security and/or participant are voided. The footnote #20 basically admits to this when it says that a direct service would \"not likely be compatible with regulatory requirements\", implying that this indirect transaction clearing service is specifically aimed at \"avoiding\" those requirements. That means this rule basically breaks the law but in an indirect way.

Under this rule, shares of various companies are not supposed to be fungible, ergo equal in value on any given day, yet this rule would make them exactly that, not considering company leadership, market cap, growth potential, etc.

This rule seems to fly exactly in the opposite direction of how a fair market is supposed to work, and correspondingly, gives the bad market actors a carte blanche for cheating and the system and motivates many remaining good market actors to throw caution to the wind and join in the crime. At the same time, retail has ZERO access to this venue which creates a virtually communist system where potentiality and innovation are completely disregarded.

It's a heinous rule for retail investors and only serves the rogue market players.

A concerned retail investor