Apr. 20, 2022
To whom it may concern, The propsed rule Change SR-NSCC-2022-801 is an afront to everyone who understands the word obligation. Obligations are to be settled - not replaced by other obligations which are wearing suits of other obligations. This rule is not in favour of all market participants as a whole. it is a one sided proposal favouring big players who somehow managed to pile up more obligations than they could handle. To big to fail, eh? This needs to stop! A similar approach was propsed by SR-NSCC-2021-010 which was equally one sided and luckily got not implemented. Less complexity more settling please! This rule CANNOT make it past the comment stage! Sincearly David Terbeek Retail Investor Germany