Supplemental Liquidity Deposits to National Securities Clearing Corporation Clearing Fund

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a National Securities Clearing Corporation (NSCC) proposals to institute supplemental liquidity deposits to NSCC’s clearing fund designed to increase liquidity resources to meet its liquidity needs (SLD Proposal), SR-NSCC-2013-02 and SR-NSCC-2013-802.  SIFMA remains concerned about certain aspects of the proposal, which is complex and could have far-reaching impacts on both the business and capital models of a broad range of market participants as well as the broader financial system. As a threshold matter, SIFMA believes that the NSCC has failed to articulate a substantive basis for the SLD Proposal, and that the proposal is fundamentally flawed because it lacks an adequate risk-based justification and would result in the supplemental liquidity deposit obligations of NSCC’s member firms being dependent from year to year on the NSCC’s success in obtaining commitments under its revolving credit facility.