Subject: SR-NSCC-2022-801
From: Brendan Nostrant
Affiliation:

Apr. 20, 2022

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To whom it may concern,
The idea that a financial obligation or more specifically a FTD can simply be "novated" as a strategy for avoiding the consequences of said financial obligation is fundamentally unfair. If I could as a consumer of debt treat my debt as fungible and swap my debt for something that was an equal representation as the original debt but not equal in value that would be great for me. Alas, I don't have access to a "dark pool" to obfuscate my financial obligations with conjured words like "novate" which my phone refuses to even recognize as a real word. The concept of "novation" is reminiscent of "Mortgage default swap" and we all know what a great thing those were for the average American. One of the goals of the SEC is to support fair and transparent markets, allowing rule SR-NSCC-2022-108 to pass is moving in a direction diametrically opposed to that goal. My vote as a taxpaying citizen is "NO!" to rule change SR-NSCC-2022-108.
Thank you,
Brendan Nostrant

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