Apr. 21, 2022
Hello SEC, In reading and perusing the 188 page document, I will first note that it is filled with jargon that is not so easily discernible to everyday investors. However, it does appear that the proposed amendments by the NSCC are a very one sided opinion of the need of this amendment. That being the needs of institutions lending and borrowing securities with a KNOWN RISK, and now doing their best to amend the rules to LIMIT and control the risk in their favor. The need to liquidate stocks to pay for settlement of other trades is part of the known risks involved by all parties. It is the same criteria that everyday people need to make on a different scale if they don't have the money to pay their FINANCIAL OBLIGATIONS. Sell an asset to pay for a financial obligation. The financial firms making these trades are fully aware of the consequences (ie RISK), just as everyday investors are aware of the risks of their trades. The NSCC claims that " When evaluating the opportunity to expand its cleared offerings to SFTs, NSCC engaged in extensive discussions with numerous market participants, including agent lenders, brokers, institutional firms, and critical third parties, such as matching service providers and books and records service providers. NSCC also organized several industry working groups to discuss the possibility of clearing SFTs" One side that they appear to have not engaged in the discussion is the INDIVIDUAL investors of today, also referred to as RETAIL. Changing the rules of how these institutions are able to hide/limit FTDs and give an essential "get out of jail free" card to short sellers overleveraged in stock trades ALREADY made is the exact process by which individual investors will lose faith in the structure of the Stock Market. Respectfully- Christian Richardson (a concerned everyday investor)