Apr. 20, 2022
To whom it may concern, This proposal (SR-NSCC-2022-003) creates blatantly unlevel ground on which the market is expected to function. Allowing FTDs to circumvent the open markets on a day-by-day basis prohibits fair price discovery and allows members to take on what would otherwise be entirely unmanageable risk. If market participants can take on large naked positions without the corresponding risk, it is clear that we are not participating in a fair and free market. That risk must offload somewhere, and with this rule proposal, that risk is being put onto the wrong parties.