Apr. 20, 2022
The proposed rule SR-NSCC-2022-003 as an egregious attempt at mitigating fire sale and liquidity drain in the market. This filling only compounds the already volatile market but ensure to create a less transparent and unfair market by adding an unknown amount of shares to a security's total float, further widening its true market value. Not only does this hurt securities it can also be used to remove an income stream from non-sponsored institutions by circumventing legitimate share borrowing and replacing it with Failure-to-deliver or "Naked Shorts" which is already a problem in multiple companies. Creating a larger netting pool in the NSCC will create an exponentially worse problem in the future and losing any trust in the markets. Further proposals of this nature should be discarded.