Subject: SR-NSCC-2022-003
From: Shorty Research
Affiliation:

Apr. 21, 2022



About proposal SR-NSCC-2022-003,


We need financial reform and financial transparency, not more rules that allow Failure to Delivers to be hidden through another obfuscated system.


The DTCC has been aware since even before the financial crisis of 2008 that the FTD's in the system that they have full monitor over are rampant, abused, and a big issue. The DTCC has been hesitant at best and ignorant at worst when it comes to handling this, and requests for that information are frequently denied or outright ignored. Don't even pretend to go out there and say times have changed since then because we all know that the financial industry walked away spot free and in fact lobbied for an even less regulated system.


I get that you're trying to save the system from itself in the case of potential mass liquidations/insolvency, but allowing corporations to not have to cover fully introduces more potential abuse not just now, but in the future as well. In simple terms, nobody learns from their mistakes if you keep pretending they aren’t doing anything wrong. In fact, knowing about potential issues and not just continually can kicking any meaningful changes, but outright refusing them makes you complicit in the problem. The systems and corporations of Wall Street have shown time and time again that it fails to be self regulating in any meaningful way that doesn't impact the global economy negatively.


Yes FTD's are a problem but, again, making them less needed to be covered and more obfuscated by rules makes it so big firms have more potential points of entropy to work with and abuse. This is an absolutely terrible proposal in that regard. You can't just stare at a melting down generator until long past the point of no return without doing anything to try to fix it before getting ready to run without telling anyone that's what you're doing.


It's been said before by others many times and I'll say it again:


This proposal is vehemently in opposition to what should be considered a free and fair market and as such I strongly oppose it’s implementation.


Good Day,
Shorty Research