Dear Securities and Exchange Commission,
firmly do not support these rule changes proposed by File Number SR-NSCC-2023-003, SR-FICC-2023-004, and SR-DTC-2023-003.
The proposed rule change consists of modifications to the Framework to clarify the Clearing Agencies’ practices concerning the valuation of:
(i) securities eligible for clearance and settlement processing by the applicable Clearing Agency and
(ii) with respect to the CCPs, eligible securities in their respective Clearing Funds (each, a “CUSIP”). Specifically, the proposed rule change would clarify certain aspects of the Framework concerning
(i) the selection of third-party pricing vendors (“Pricing Vendors”);
(ii) the monitoring and review of Pricing Vendor data;
(iii) the processing and use of Pricing Vendor data;
(iv) other non-substantive aspects of the Framework
I do not support this because it gives power to other parties to adjust pricing for stocks that is well outside a price set by traders in a security, where the price is set by buyers and sellers.
This change will significantly reduce or eliminate the marketplace from truly be a market.
I firmly do not support these rules changes.