Subject: SR–NSCC– 2022–801
From: Jared Knupp
Affiliation:

Apr. 19, 2022

To whom this may find, 


This rule appears to proposes using a vehicle, they call an SFT (Securities Financial Transaction), as a placeholder for any securities transaction, in an attempt to darken an already dimly lit exchange. As I understand it, these SFTs are fungible like a dollar bill. So, if you have 100 worth of SFT that you are on the hook for and Fail to Deliver, rather than buy-in at market value, you can resolve it by utilizing another SFT worth the same amount set for the same delivery date. The cost one would pay for this "feature" would be based on the difference in closing price from one day to the next. This cost would be much cheaper than a market buy-in, especially when after hours trading is used widely to reboot their books. Seems like a cheap way to can-kick a scary-ass FTD problem, rather than buy-in at current market value. I.e. seems crafted to protect the abusive trading practices that are further creating a market that has a diminishing foundation. 


Jared K.