Apr. 20, 2022
To whom it may concern, My name is Justin Safier. I'm 25 years old and have lived in New Jersey my entire life. My concerns with rule SR-NSCC-2022-003 is that this is entirely treating a symptom (FTDs) while simultaneously allowing the disease to get far worse (naked-shorting and overleveraged brokers and hedge funds) by allowing the NSCC to centrally clear SFTs. On page 3 of the bill, it defines SFTs as the following SFTs involve the owner of securities (typically a registered investment company, pension plan, sovereign wealth fund or other institutional firm) transferring those securities temporarily to a borrower (typically a hedge fund). SFTs are often facilitated and intermediated by broker- dealers and agent lenders (i.e., custodial banks or other institutions that lend out securities as agent on behalf of institutional firms). At the same point, a footnote of an official letter from the then VP of the NSCC to the SEC wrote the following as a footnote in a letter they sent to the SEC (src:Comments of National Securities Clearing Corporation on S7-27-03) NSCC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation, which in turn, is owned by its principal users -- major banks, broker- dealers, mutual fund firms and other companies within the financial services industry. DTCC's Board of Directors is made up of 21 directors who also serve as directors of NSCC. So with the context of these two points, The NSCC, which is a subsidiary of the DTCC, is owned by the same exact kinds of businesses that would need to take advantage of SFTs? This at the very least is yet another form of brushing the current problems with Wall Street under the rug and continuing to allow that bulge in the rug to become larger and larger. In all of US history, anytime that we as a country have tried to brush things under the rug, it's blown up in our faces in a way that was multiple times worse then if we just dealt with it when we should've. Thank you for reading this, Justin Safier