April 20, 2022
I am commenting as a \"NO\" to this rule.
This reads as a rule to launder illegal naked shorts persistent FTDs
The NSCC explicitly understands that there are significant FTDs, Naked Shorts and similar that need to be cleared. This rule proposes a service to avoid those pesky obligations. It does so by introducing a new transaction layer that novates (replaces) old obligations b/w NSCC member lender / short sellers / prime brokers / etc. with a new obligation b/w a member and the NSCC itself as the new counterparty. This novation is done with even more lending of securities.
This rule has been withdrawn twice already and this is the third time it has been introduced.
I believe this rules sole purpose is to defend and hide \"bad actors\" naked short selling which has been allowed to proliferate through swaps and other derivatives.
These firms/individuals must be held accountable for their naked shorts and FTD's no matter whom they may be
Once again I vote \"NO\" with great prejudice to this rule