Apr. 20, 2022
Good day, The following is my comment for File Number SR-NSCC-2022-003: Understand that I have read the document in full and comprehend the language and terms used. "NSCC is proposing to introduce central clearing for SFTs, which are, broadly speaking, securities lending transactions where parties exchange equity securities against cash and simultaneously agree to exchange the same securities and cash, plus or minus a rate payment, on a future date.' In short, this rule seems like a very convenient way for hedge funds to ignore the potentially infinite - albeit infrequent - risk that short selling inherently has. We may indeed find the market in the peculiar condition that the infinite risk of short selling has come into practice - it is indeed rare - but it is nonetheless here, right now. A rule change to limit the fallout of said risk is an inherently dishonest move by the SEC, and threatens the underlying trust and symbolism of the market that holds it all together. You simply cannot ignore or change the fact that speculation entails risk. Best Regards, Connor Brewin