Apr. 20, 2022
To whom it may concern, The proposed rule adds yet another shell to an already bloated shell-game. Centralizing clearing for SFT’s increases obfuscation of an already systemic issue- securities are being traded when available shares do not exist, bloating the total quantity beyond what the underlying company issued. Creating a banking process for this, run by the NSCC, which is run by the private banking system, with zero independent or federal oversight, is asking to exacerbate this issue. They say this request is in the name of ‘efficiency’ & ‘risk-mitigation’, but these changes just allow for another shell to hide fraud behind. Please withdraw/deny this proposal, it further undermines market integrity. Best, Sam Love