Apr. 20, 2022
To whom it may concern: This was sent in response to SR-NSCC-2022-003 as well but covering both as they seem to be two separate but identical rules (this is the advanced notice variant) Any rules created that allow ignoring the fiduciary responsibility of an entity participating in our markets should not be passed. All this rule does is allow one entity to pass their responsibility onto another entity and "reset" the clock in failure-to-deliver obligations. There is already enough rule breaking and bending in our markets; do not add a legal way for an entity to skirt their responsibilities. Regards, Stephen Ranger