June 23, 2021
This Rule should be better explained to the public.
From Reading the Rule change it sounds like the DTCC now has the ability to suspend any Action,enforcement of existing rules and deadlines by a indefinite amount of time which would exactly counter newly added rules like NSCC-002 for example.
From past experiences it seems like the DTCC doenst like enforcing existing rules so giving them the ability to postpone anything by a undefinded amount of time is a dangerous action.
Until further clarification on a specific timeframe to extend the timeframe for anything it should be cleary stated in the filing (a maximum of 12 hours should be appropiate for this) this rulechange should be negated because with this rulechange the DTCC would not enforce any existing rule at all and the US Security market is already in huge danger.
1. Add a specific and maximum timeframe they are able to extend timelines for (12 hours max)
2. Disable this rulechange
3. Clarify to the public and retail investors what this rulechange exactly does because currently it sounds like it lets the DTCC disable and extend the Timeframe of any existing rule indefinitly i.e. never acting on it which is really dangerous for the US eco system.
with kind regards
Toni Metzger