April 20, 2022
This regulation is simply offering MM's the opportunity to further hide and deflect Failure to delivers on shares. This is simply a watered down version of SR-NSCC-2021-010
Since this was already removed due to conflicting interests from MM's regarding rolling Call contracts forward in order to hide Long term short positions. Essentially using contracts to cover short positions which need to be covered. These FTD's must be investigated instead of hidden from the public.
Please act in the interests of market stability and ensure failure to delivers are not allowed to be excused and must be covered with actual shares instead of contracts.