Apr. 08, 2021
To all interested parties, There are several areas that have a serious lack of oversight within the US financial system. The SR-NSCC-2021-801 is an extremely positive step in the right direction for modern financial market oversight and should be applied with immediate effect. Combined with SR-DTC-2021-003 and SR-DTC-2021-005 federal regulations can begin to counteract shady delayed processing and active subterfuge of retail and other non-OTC transactions for the benefit of those with access to these markets. The increase of darkpool trading and the increase of abuse of the failure-to-deliver mechanism, options convertibles and other obfuscated trading practices in today's market is extremely troubling. Combined with the extreme lack of transparency in OTC dark pool markets and high frequency trading there is almost no chance for a retailer to participate in a free market. SR-NSCC-2021-801 provides the necessary steps to prevent intentional gaming of market makers and their affiliate organizations. Application of SR-NSCC-2021-801 should begin to prevent inducing extra risk into the clearing corporation and the rest of the market by limiting the amount of outstanding assets to be rehypothecated through non-cash collateral and by increasing transparency. I posit that there is never a liquidity requirement that should require the rehypothecation of assets in the options markets and should be considered extremely rare. This extremely aggressive activity should be reported on daily and aggressively challenged. This daily reporting is easily achievable with modern technology. Regards, J.D. Cumpson