Apr. 19, 2022
To the Commission requesting comments regarding rule proposal SR-NSCC-2022-003: By my understanding of the proposal, the proposed vehicle called an SFT is fungible, such that utilizing one SFT matching certain criteria could be used to satisfy another SFT. This rule seems like it can be used to avoid obligations of satisfying certain security transactions, potentially indefinitely, by swapping SFT that a party is trying to avoid with another SFT. This rule seems like it can create a loophole or rule that allows a party to indefinitely kick the can down the road and never have to be accountable for satisfying certain security transactions. I am against this role as it increases the complexity of our markets by introducing new rules and possibly loopholes around settlement of security transactions, which I believe should be as simple as possible to maintain transparency and trust in the markets. Thank you for your time, A retail investor.