April 24, 2022
Dear SEC,
Subject: Release No. 34-94694 File No. SR-NSCC-2022-003)
I am opposed to the proposed rule.
The NSCC - SFT Clearing Service Program presents another \"loophole\" for the entities which results in a reduction of \"margin requirements\" by limiting the positions that need to be liquidated to the defaulters net positions.
One of the major issues is when I ran into this statement: \"NSCC understands that SFTs
provide liquidity to markets and facilitates the ability of market participants to make
delivery on short-sales, and thereby avoid failures to deliver, naked shorts, and similar
situations.\" pg. 10
Such a situation would massively hurt the transparency of the market and depress the prices of securities.
It is unethical for the \"Buy-In\" to be determined by NSCC based on the
opinion of NSCC whether or not, such Buy-In would create a disorderly market in the relevant SFT Security.
This opens a door of conflict where NSCC would NOT require Buy-Ins according to their own opinion.
Also, the proposed SFT Clearing Service would lend or borrow a security without EVER owning the Relative Security which hinders price discovery and generates continual synthetics.
I reject this ruling from being passed because it hurts us Retail Investors and creates an unfair and disorderly market.
Thank You,