February 12, 2022
As a retail investor I do not support this proposal. This will be used to maliciously wash FTDs and further encourage naked short sales in the ecosystem. The NSCC should consider rules that reduce and discourage naked short sales. You are not operating in the shadows anymore . Everyone is aware of the rampant fraud that your systems enable. As an SRO You have completely failed. The NSCC should implement rules that require mandatory buy-ins when FTDs occur and absolve support structures for FTRs, FTDs and any resemblance of fractional reserve stock systems. There are obviously significantly more trades occurring than shares that exist in your entire book entry system. The NSCC should consider modernize computer solutions that leverage instant settlement systems such as blockchain or ledger technology. It should be the NSCCs focus to abolish any lending facilities that exist internally to the DTCC. The only eligible party that should be entitlement to loan shares should be the beneficial owner of the share not the custodian of the shares. All share lending should require written consent from the street name holder of the security with explicit terms of the loan and returning of the security on a preset timeline. The NSCC should consider rules and proposals that protect the shareholder rights of individuals that hold securities in street name. The NSCC should consider making all details of their internal clearing and CNS systems available to the public. The NACC should consider publishing the obligation warehouse another vehicles for hiding failure to delivers. The NSCC should consider drafting rules that discourage abusing over leveraged trading practices that put our entire nation and the worlds reserve currency at risk for insolvency. The NSCC should consider new leadership that prioritizes the needs of a healthier and more stable stock market ecosystem. The NSCC should consider lots of things.. none of which should resemble anything close to this proposal. No more lending facilities. No more short sale protections. Naked short selling is illegal - covering up naked short sales in an effort to reduce market impacts is a clear ethical violation. The NSCC should consider morality when proposing new rules.