Apr. 20, 2022
Dear sir or madam, I am writing to express my concerns about SR-NSCC-2022-003 and to state that it should never be implemented.. As I understand, it has been withdrawn twice, which tells me that it needs to be withdrawn completely. As the rule is written, the NSCC is trying to help offload FTDs (Failures to Deliver) so that there are no forced buy-ins/delayed buy-ins from Hedge Funds/Market Makers who have gotten themselves in trouble. My belief is that at no point should an entity, NSCC or otherwise, take on the responsibility of a bad actor who cannot deliver what they sold in a timely manner. Forced buys-in should be required and no method to delay that should be allowed, otherwise it is delayed theft in my opinion. I believe that if this rule is officially shot down by commenters, it should be removed altogether. The SEC and NSCC need to protect the rights of retail. That does not appear to be the case in our current times. By not implementing this rule, you are, at least, making a step in the right direction. Thank you, Kevin Wood