Apr. 20, 2022
Good Afternoon, I believe the proposed change would not be a benefit for retail and would be a step backwards with regards to creating a transparent and free market. There are many parts of the proposed rule that looks concerning to me, especially considering the SFT Clearing Service that is being proposed is an attempt to clear trades under the table. The part of the proposed rule change that has especially got my attention is on page 11 with the following statement: NSCC has determined that overnight term SFTs with a daily pair off option are more appropriate for the proposed SFT Clearing Service than open transactions with mark-to-market collections. The statement above is making a case saying that the SFT Clearing Service is more appropriate than open transactions. That sure sounds like a statement looking to reduce transparency to me. I have a career to concern myself with and cannot dig through a 188 page document for every detail but if I found this 12 pages in, I can only imagine what other concerns lurk in this. Not for retail. Have a good day, Travis Russell