Apr. 20, 2022
Hello Mr. Chairperson, As I understand it, this rule proposes using a vehicle the NSCC is calling an SFT (Securities Financial Transaction ... ), as a placeholder for any securities transaction. These SFTs are fungible like US currency. So, if you have 100 worth of SFT that you SHORTED, and want to 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 the floor for a security is like $1,000,000.00. Seems like a cheap way to can-kick a FTD problem (idiosyncratic risk anyone?), rather than buy-in at current market value and thereby close the legal obligation. This seems crafted to protect the practice of abusive short-selling when it doesn't work out for the HF / MM. Someone has to be the counter party to this trade. This just creates a secondary market ( another form of DARK POOL ) connected to the primary one, another loop through which to cycle FTD’s. More “piping” to manipulate through which can spread “fake” shares in the name of “liquidity”. For every layer of complexity added, even more liquidity can be taken from the markets, from investors and publicly traded companies who trying to achieve something good for themselves and this world. In essence, this practice of extracting liquidity ( taking currency out of the markets and giving it to the HF / MM stakeholders ) and replacing it with IOU’s and synthetic securities is creating a further liquidity crisis requiring a “bailout” at some point and does nothing to address the actual cause, abuses, and crisis. 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. This novation is done with even more lending of securities that may in and of themselves ( securities ) may already be synthetic. Assuming no significant changes from 2021-010, this is a rule to sidestep other rules in place to hold members accountable and prevent illegal naked shorts & persistent FTD’s. This proposal is not in the interest of RETAIL. This does NOT lead to Transparency or hold those who have put this country at risk accountable. SR-NSCC-2022-801 is the advance notice. "We are going to naked short. If we can't locate or don’t want to pay the buy-in, instead of FTD we are going to create a temporary IOU and when the time comes, if we can't locate or the price to buy-in is too costly, again we are going to create another IOU to replace the original IOU and keep getting away with FTD’s." Please let me know if you have any questions. Thank you and have a nice day! Thank You, Wayne Gatewood L & L Logistics and Warehousing, Inc. L & L Trucking Company 279 E. Redondo Beach Blvd. Gardena, CA 90248 Tel# 310-527-2599 Fax# 310-527-6558 Cell# 424-675-0484 www.landllogistics.com ____________________________________________________________________ This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received it in error, please notify the sender immediately and delete the original. Any use or transmission of any part of this email is prohibited.