April 20, 2022
I am extremely concerned with the proposed rule changes in SR-NSCC-2022-801.
The creation of SFTs adds a layer of obfuscation to the clearing system which is the last thing that needs to happen. Unlimited liquidity is not worth obscuring the actual underlying transactions.
The complexities of the current market are what have allowed systemic risks to our economy to manifest. The leveraging, derivatives, swaps, and more have all created a system where FTDs are at an all time high.
This is not the time to hide the FTDs or allow alternative settlements. This is the time to address the issue and force delivery of these securities.
SFTs enable actors to avoid their responsibilities to act in good faith during any securities transaction. We need to use our modern tools to force deliveries of securities instead of enabling a new way to avoiding delivery