diff --git a/Regulations/SR-NSCC-2021-006/2021-05-08-Breakdown-of-NSCC-006.md b/Regulations/SR-NSCC-2021-006/2021-05-08-Breakdown-of-NSCC-006.md new file mode 100644 index 0000000..a1d8bc2 --- /dev/null +++ b/Regulations/SR-NSCC-2021-006/2021-05-08-Breakdown-of-NSCC-006.md @@ -0,0 +1,36 @@ +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/) | + +--- + +[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.