Subject: NO SR-NSCC-2022-003
From: Sean McKeon
Affiliation:

Apr. 20, 2022

 


Not a fan of this rule change. Novating obligations doesn't sound like it would make the market fairer. Why add unneeded complexity to the Market? FTDs are already a huge problem and this is another mechanism to avoid closing positions. Do not implement SR-NSCC-2022-003.