May. 30, 2023
The proposal entitled “SR-NSCC-2023-005 Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend the Clearing Agency Investment Policy) is significantly redacted which prevents public review making it impossible for the public to meaningfully comment on this proposal; so this proposal should be rejected on that basis alone. The proposed rule changes for "the manner in which each of the Clearing Agencies identifies, measures, monitors, and manages the risks related to the pricing of securities processed or otherwise held by such Clearing Agencies" including "the monitoring, reviewing and processing of pricing data for end-of-day and intraday pricing" directly affects the investor protection and public interest and can not be meaningfully commented upon by the public when the exhibits provided are entirely redacted. As the redactions render it impossible for the public to meaningfully review the proposed changes to the Framework which clearly impacts the pricing of securities, this proposal should be rejected._Be open and stop hiding If the proposed changes are merely corrections, clarifications, and simplifications, then the proposed changes should be made available for public review instead of hidden in redacted exhibits. Obscuring proposed changes from public review, followed by approval and implementation, reduces the already dwindling public trust in both our SIFMUs and their regulators. - Michael Gilbert & Family