April 20, 2022
SR-NSCC-2022-003 raises the concern that the profit motive of a shareholder-owned SRO could detract from proper self- regulation. In particular the careless granting of exemptions to well-made banking regulations
The SECs mandate is to maintain the market, not to tilt it in favor of granting ever more liquidity to SROs and their lenders and brokers. By allowing market participants to engage in overnight IOUs instead of delivering the securities they sold. If you let this rule pass, you are subverting your own mandate and the spirit of regSHO you are inviting market participants to gamble our way into another 2008-style crash.