Subject: SR-NSCC-2022-003

Apr. 19, 2022



This rule proposes using a vehicle, they call an SFT (Securities Financial Transaction ... sigh), as a placeholder for any securities transaction.  As I understand it, these SFTs are fungible like a dollar bill.  So, if you have 100 worth of SFT that you SHORTED, and want to Fail to Deliver rather than buy-in at market value, you can resolve it by utilizing another SFT worth the same amount set for the same delivery date.

This letter to the SEC, I highlighted that the complexity of rules that govern our fail (oops, Freudian) fair market, are not created by Retail, rather by Wall Street, big banks, and Hedge funds, and they use the complexity to their advantage.  This rule is just another example of leveraging complexity to fleece over retail by keeping them ignorant.
This is not helping retail, and you know it.