Subject: FW: Comments on File number 4-853
From: Michael Koehler
Affiliation:
$250 million is a pretty low annual cost. Less than $2 a year per retail investor participant. The stock market is pushing $100 trillion in raw value, some estimates of derivatives are into the quadrillions. What's a quarter billion to watch over that? Its pennies.
Furthermore, as far as I understand, you're proposing to kneecap CAT before it's even implemented. A considerable amount of participants are still on exemptions or waivers, correct? Which makes it only a partial implementation. So we don't even know the impact. But even with a half baked implementation, we do know major players are failing these at highly concerning rates. Didn't this just week it whistleblow goldman sachs on tens of billions of improperly recorded trades? JP Morgan the same a couple months ago?
So let's set the record straight. It isn't a high cost, I'm happy to pay my $2; you are not in a position to determine its full effectiveness, since not covering the whole market; and it is already turning up eyebrow raising results, and we concerned investors, who see bad faith left, right, and center, like seeing those results. And although we know you do not care for us, we are here. So let's not jump the gun on getting rid of oversight, especially if you're going to cite such a low cost as the deciding factor.
Thanks,
Michael