Subject: File No. SR-NSCC-2022-003
From: Christopher Britt
Affiliation: School District 48

April 20, 2022

The NSCC explicitly understands that there are significant FTDs, Naked Shorts and similar that need to be cleared. This rule proposes a service to avoid those pesky obligations. It does so by introducing a new transaction layer that novates (replaces) old obligations b/w NSCC member lender / short sellers / prime brokers / etc. with a new obligation b/w a member and the NSCC itself as the new counterparty. This novation is done with even more lending of securities.
This rule change will only ensure the major money makers who move more capital than the entire American economy, will continue to put our entire financial system at risk.

You can't allow these already irresponsibly large money makers to further avoid financial accountability under the vail of securing the markets.

What this rule does, is entirely the opposite. You need to improve our markets, little by little, not doubling down on a nuclear decision to protect those with too much power.