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Create 2021-05-08-Breakdown-of-NSCC-006.md

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NSCC-006 doesn't change much, but looking forward to other changes.
===================================================================
| Author | Source |
| :-------------: |:-------------:|
| [u/bavetta](https://www.reddit.com/user/bavetta/) | [Reddit](https://www.reddit.com/r/Superstonk/comments/n7jphk/nscc006_doesnt_change_much_but_looking_forward_to/) |
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[DD 👨‍🔬](https://www.reddit.com/r/Superstonk/search?q=flair_name%3A%22DD%20%F0%9F%91%A8%E2%80%8D%F0%9F%94%AC%22&restrict_sr=1)
What did the [NSCC-006](https://www.dtcc.com/-/media/Files/Downloads/legal/rule-filings/2021/NSCC/SR-NSCC-2021-006.pdf) change do?
First, note that NSCC Rules aren't exactly the same as Procedures. You can see that the Rules and Procedures are listed separately [here](https://www.dtcc.com/~/media/Files/Downloads/legal/rules/nscc_rules.pdf). Procedures seem to describe how the NSCC runs, and Rules are more like regulations. They are pretty similar though.
I've seen talk about [NSCC-002](https://www.dtcc.com/-/media/Files/Downloads/legal/rule-filings/2021/NSCC/SR-NSCC-2021-002.pdf) being potentially approved Monday because of NSCC-006. That doesn't make sense to me.
1. NSCC-002 still needs SEC approval.
2. The SEC just announced a new public comment period for NSCC-002 which ends 5/31 (submit comments [here](https://www.sec.gov/rules/sro/nscc.htm#SR-NSCC-2021-002)). The SEC wouldn't cut their new public comment period short.
3. NSCC-002 is a Rule change (not a Procedure change), and the pertinent change in NSCC-006 only reduces the notice period for Procedure changes.
NSCC-006 is mostly a formatting update. Here are the few minor things I found interesting:
1. Changes to Procedures no longer need a 10-day notice. Allows the NSCC to act more quickly for operational changes - but remember, Procedures aren't the same as Rules. Rules never had a 10 day requirement.
2. Adds "Procedures" in the Rule Change section. This could actually make a Procedure change slightly more difficult, requiring the NSCC to now collect comments and deliver the comments to the SEC.
3. Changes how fast the NSCC notifies members about new changes from "immediately" to "promptly". So, could they potentially file a change to the SEC without notifying their members right away - perhaps to catch them off-guard? I think this is more likely a legal hedge with regards to "what does immediately mean?", whereas "promptly" promises less.
All-in-all, pretty much just a formatting update (capitalizing certain words, replacing acronyms in other places, etc). There are good changes lined up ([NSCC-002](https://www.reddit.com/r/Superstonk/comments/n445l7/timelines_for_nscc801_and_nscc002_approvals/), OCC-004, DTC-005), but NSCC-006 isn't one of them.
It does indicate someone is taking a close look at the rules though. Someone wants to make sure there are no loopholes...
Disclaimer: I am not an expert. I don't know what I'm talking about. Do your own research before trusting anything here.