May 31, 2023
Subject: Comments on SR-DTC-2023-005 The proposal entitled “Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend the Clearing Agency Investment Policy,” (SR-DTC-2023-005) 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 to amend the Clearing Agency Risk Management Framework directly affects the investor protection and public interest and can not be meaningfully commented upon by the public when the exhibits provided are almost 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. Additional examples for why this proposal should be rejected include: a) Eliminating a dashboard in preference for multiple dashboards does not necessarily allow for a more holistic view of the performance of the Clearing Agencies and their subsidiaries. Changes in how information is reported and/or separating key information across multiple information sources may obfuscate key performance information that would otherwise allow significant changes in performance to be identified. b) Changes to the "Three Lines of Defense" risk management model should be more carefully reviewed for unintended consequences that may increase risk, especially for SIFMUs. Unfortunately, the redactions prevent public review which limits the public's ability to assess the potential impact of the proposed changes. c) Grammatical changes should be made available for public review. While the proposed changes are presented as minor, the actual changes are redacted from public review. Even minor grammatical differences may have significant impact as evidenced by a single Oxford comma leading to a $5M settlement for delivery drivers in Portland, Maine. 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. Therefore, the Commission should suspend and reject proposed rule changes with heavily redacted exhibits, including SR-DTC-2023-005 as the interested public can not review these changes, investors can not determine whether or not these changes protect or harm them, and the public can not determine if the proposal is consistent with the Securities Exchange Act of 1934 for ensuring a transparent and fair environment for investors where, for example, the redactions eliminate transparency into whether or not these proposed rule changes are fair for investors. Sincerely, J.S. Laskar, Investor