April 20, 2022
I write in opposition to the adoption of the proposed rule changes set forth in SR-NSCC-2022-003. The proposed SFT system is a cartel intended to control prices through dampening volatility in the securities market. Only approved entities are entitled to participate based upon loosely disclosed parameters. Under the proposed change for section 9(b), the NSCC is entitled to set a \"deemed price\" to finalize transactions rather than be tied to a published price on a lit exchange. Frankly, if this proposed system were lined up against the club requirements for a country club, they would read the same. There is an entry fee, but NSCC might still determine that you can't play. A member can sponsor you, but will be responsible for your divets. Score cards may be reviewed only by club members. Club members can watch and participate in games around the world, but no one can watch club member games. The opaque world of institutional trading becomes more so with this proposed rule. Price discovery is dampened by the NSCC's risk absorption and settlement delay. Retail loses out on profitable trades that become available when markets are volatile. Staff should review NSCC proposal under antitrust laws.