Subject: NSCC-2022-003 - Rule Comment
From: Jack Vanstone
Affiliation:

Apr. 20, 2022

Hi SEC,

I can't express enough how unbelievably furious I am having read such an egregious rule proposition. FTD's and the lack of enforcement regarding the settlement of obligations are one of the key problems in securities markets as they enable excessive and indefinite market manipulation to go completely unchecked and unregulated. 

This is now the third time that the NSCC has attempted to sneak this immoral and completely illogical rule passed retail investors and it's starting to become quite clear what the intention is - to allow short sellers and large market participants such as Citadel and Virtu to continue abusing market mechanics at the detriment of a free and fair market. 

This proposed rule undermines democracy and the rule of law. A failure to deliver is when you FAIL TO DELIVER on your obligation to settle a short sold security, so why is it that one of the largest SRO's in the world is proposing a rule change which enables them and their financial crime syndicate to engage in indefinite can-kicking with no responsibility for the implications of their actions? It's because they are trying to avoid accountability and so they can continue to scalp swaths of generational wealth from the worlds population through underhanded means which they have become all too accustomed to. 

This proposal on SFT's and the implications it would have on the market is quite frankly, abhorrent. These SRO's and market makers are making an absolute mockery out of the American financial system, the whole world is watching and the sheer gaul to propose such a rule is simply astounding. 

If the SEC is truly wanting to fight for a fairer market I suggest that this rule is not only denied, but that any further application to the same affect be met with an immediate dismissal, on the grounds that the proposed rule change holds no merit (as evidenced by the 2 previous dismissals of the same rule) and because it presents a significant systemic risk to securities markets which are already in turmoil due to decades of deplorable actions by the NSCC, DTCC, Citadel, Goldman and others. 

Regards, 
Jack Vanstone