Subject: Comment on File Number SR-NSCC-2022-003
From: Bibic Jr
Affiliation:

Apr. 20, 2022

 


This rule looks disastrous. It places liquidity above all else. Liquidity is important, but not at the risk of the entire market collapsing under phantom/naked securities. 


Is it really liquidity if the asset is never delivered? Or is it just taking money in exchange for an IOU? 


As an individual investor I want to be sure that when I buy a share, it is actually delivered. Otherwise the liquidity means nothing. 


This rule appears to only create more complexities through which hedge funds can abuse FTDs. 


FTDs should be more of a priority than liquidity if you intend to make the market more fair.