April 20, 2022
I vehemently oppose rule change SR-NSCC-2022-801.
Its a rule to launder illegal naked shorts persistent FTDs. Question, How about making Market makers / Hedge Funds deliver their fucking shares like the rest of retail has to? This is absolute bullshit.
The NSCC explicitly understands that there are significant FTDs, Naked Shorts and similar that need to be cleared. This rule proposes a service to avoid those pesky obligations. It does so by introducing a new transaction layer that novates (replaces) old obligations b/w NSCC member lender / short sellers / prime brokers / etc. with a new obligation b/w a member and the NSCC itself as the new counterparty. WTF. This novation is done with even more lending of securities. How the fuck does this even begin to solve the problem of naked shorting and FTD obligations? Fuck this proposal.