Apr. 20, 2022
To Whom It May Concern: The proposed Rule SR-NSCC-2022-801 to establish a Securities Financial Transaction (SFT) vehicle for the purpose of "novation" spits in the face of the "Free Market" which the SEC and the United States financial system purportedly prides itself on. These SFTs serve to only to obscure the underlying transactions and to "sweep under the rug" transactions that may be troublesome for institutions, namely persistent FTDs and naked short selling. Let me be clear, the aforementioned proposed rule presents a significant moral hazard for the markets at large. If this proposed rule passes, a blank check is presented on a silver platter for bad actors with the Authorized Participant and market maker designation to essentially print money (i.e. financial instruments) with no recourse and little accountability. This is dangerous for the integrity of the financial system and economic system in general and fundamentally opposes the SEC's mandate to regulate and promote efficient markets capital formation, and price discovery. If institutions can essentially dilute the value of financial instruments, they are STEALING from retail investors that are not playing on a level playing field. This hurts capital formation as investors will become skeptical of participating in a "rigged game". Furthermore, it hurts American Companies as their business valuations are adversely and abusively affected as their stocks are open to manipulation under the veil of "providing liquidity". Everyone is taught that in economics, under the assumption of scarcity, supply and demand should drive price. If this proposed rule passes, it opens a dangerous door to an unlimited supply of financial instruments disguised as "SFTs" that should not exist. Common sense says that if you owe a debt, it should be repaid. If obligations mean nothing, the system is pointless. If the rules are not the same for everyone, and I as a retail investor cannot continuously roll my debt every day with no recourse, it is only fair that institutions be held to the same or higher standard. For the above reasons, I fundamentally and vehemently reject and oppose the proposed Rule SR-NSCC-2022-801. Regards, Nam Pham