April 22, 2022
As a shareholder of US equity I strongly disagree with the proposed rules change in the filing SR-NSCC-2022-003. My biggest concern is that the rule creates options for market makers and liquidity providers to avoid or bybpass their obligations (collateral) for held assets or other liablities (failure to delivers,...).
As I understand it, the rule is to prevent defaulting of such member in case of a firesale and market crash to keep the market going. But what the rule actualy does is making the problem bigger and does not obligate a member to cover for the liabilities with collateral. The rules makes the current economic situation worse by making it possible to cover these liablities with loans but keep risky or cost intensive assets open and not accurately manage their risk.
My humble opinion is: With this rule a market crash and short squeezes are tried to avoid and the members and players who are deeply involved and are the reason for the current marketsituation (overleveraging and Failure to delivers are never closed and payed for). The rule 003 helps increasing the problem by avoiding the inevitable and stop the market from working as free intended.
I strongly disagree with the rule SR-NSCC-2022-003 and I do not want this rule to be deployed on the market. I do vote against it. I do not want it to be active.
Best regards,
Tom Rethberg,
Germany