August 11, 2021
To the Commission,
I applaud your efforts in the Regulation NMS CT Plan filing for truly doing your job, and holding the SROs accountable, and giving the public a chance to comment on some of the concerning aspects of SRO behavior.
Based on publicly available information, it's clear the market has been fragmented in regards to market share for quite some time.
SROs have the ability to \"can-kick\" filings, procedures, and regulatory changes by various methods.
The Consolidated Audit Trail plan is a perfect example of this.
There has been more than enough time for these SROs to prepare for these long overdue changes, and the absurdity of excuses given by these entities are just that.
I believe there's a strong misconception in regards to \"experience and expertise\" when it comes to many SROs, as the former doesn't necessarily relate to the latter, especially if your \"experience\" only regards dodging regulatory action, enforcement, and by subverting all responsibility.
My comment is requesting one thing: accountability.
Fines paid are nothing more than the cost of doing business. The public are waking up to the fact that the fines associated with the crimes do not prevent the same manipulative and predatory actions.
If you haven't noticed, since late March, the market has been decaying. There's irrefutable evidence that Money Market Funds, comingled funds, joint bank accounts, ETFs, Exemptive orders surrounding those ETFs, as well as a group effort by many members and participants to keep volume off of the exchanges, and retail in the dark.
The reverse repurchase market, in my opinion, is directly linked to inflation. Gary Gensler was sworn in on April 17th, 2021, and honestly, at first, I was worried.
I can firmly say that at this point in time, I applaud the Chairman's efforts, but there remain just one area of major concern:
Investigate the repo market. Investigate the Federal Reserve. This market cannot be \"free\" if we have an entity such as the Fed convoluting with 60+ participants on a daily basis, with no dissemination of data to the public.
All volume and liquidity has dried up, yet the ETF market is booming. No options exchange currently has more than 16% market share, and has been the case for quite some time, as noted in the SROs filings themselves.
It's clear that Money Market Funds are conspiring with the Federal Reserve, as charts from the broader market, bond market, and treasury yields show clear signs of manipulative arbitrage. The 12:15 - 12:45 EST window of time that these repo transactions take place could help the Commission in uncovering what truly is wrong within our markets.
It isn't retail. They are the ONLY entities playing by the rules in this situation, something that should really be thought about.
We're running out of time to make this right, and your swift action has been much needed. Please don't stop here. We're making headway that could change these markets, and the world, for better.
Thank you.