Apr. 20, 2022
Sir or Ma'am, Advanced notice SR-NSCC-2022-801 for rule SR-NSCC-2022-003 seems to allow NSCC members to utilize SFTs on a rolling basis to mitigate Fails to Deliver, which would lead to even more of a lopsided risk in the market. This allows the short side of the trade to kick the can of security delivery practically indefinitely which eliminates their risk of having to buy back in at the market price. This would reduce the market's ability to establish a fair price for securities. Please do not allow this rule change to go any further. Very Respectfully, William Stillman