Apr. 20, 2022
Good morning, (I already sent this with the subject SR-NSCC-2022-003 as I was unsure which to send to - they seem to pertain to the same rule) Let me start by saying thank you for your work. I would imagine that being a regulator, like any enforcement entity, is rather thankless, nonetheless important work, so again thank you for your time today. Regarding SR-NSCC-2022-801 - it seems to me that this rule is greatly to the benefit of the banks/invesement funds/etc enabling them to repeatedly postpone payment of obligations over and over. Failures to deliver are one of the scourges of the current system that should not be allowed to happen, and allowing organizations to repeatedly delay fulfilment of said obligations obviously works against the individual investor. Allowing these postponements would cause further harm to the fairness of the markets - thus damaging the very existential credibility and nature of such a "self-regulating" industry. If I were to write a bad check, and then cover that bad check with another over and over, would that not be illegal and wrong? Is this rule not proposing similar by allowing a new obligation to cover an old obligation over and over without said obligation ever in fact being met? The overcomplexity of the system continually works against the people, and this rule looks to be more blatant abuse of that power. Again, thank you for your work. When reviewing rules like these it sometimes looks like these regulations are only being put into place to protect the financial industry at the cost of the people. Please remember to protect the people. -Tony Concannon