April 20, 2022
I do not support this Proposed Rule Change to Establish the Securities Financing Transaction Clearing Service and Make Other Changes. Larger funds involved with transacting in the marketplace have piled up massive amounts of failure to delivers (FTDs). This rule change would allow these funds to avoid these obligations to cover their positions and completely pass them to other entities. This is very disappointing to see. This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice. It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. How does this rule contribute to a \"fair\" market? I do not believe that this proposed rule change would allow for more transparent and fair markets.