Apr. 20, 2022
To whom it might concern, To the best of my knowledge, the NSCC explicitly understands that there are FTDs, naked shorts and similar that need to be cleared. This rule seems to propose a new vehicle ( Securities Financial Transactions) to avoid fulfilling those obligations by introducing a new transaction layer that replaces old obligations with new obligations between NSCC member lender/ short seller/ prime broker and a new member and the NSCC itself as the counter party. This appears to be done with even more lending of securities. It seems that this proposed rule will create the opportunity to naked short a stock, and if the shorts can’t locate securities, instead of FTDs they have the opportunity to create a temporary IOU, and when the time comes, if they can’t locate again, they could create another IOU to replace the original IOU and keep getting away with what is essentially a scam. It also seems that the cost of SFTs could be significantly smaller than that of FTDs. So, from my perspective, as a retail investor, this rule is not made to benefit retail, quite the opposite. Please discard it! Or remove it! Honestly, i don’t know what the terminology for this is, but stop trying to pass this rule. It’s the 3rd time when such an attempt is made. I oppose this rule! Best regards, Oana Hawgood