February 19, 2022
I support the proposed rule to shorten settlement cycles, down to t+0, to be implemented as soon as possible.
Having extended settlement times not only increases overall risk by having large amount of pending transactions in a market where significant changes occur on increasingly shorter timescales but also allows greater opportunity for purposeful fraud and abuse with regards to Failures To Deliver.
I would also support additional rules specifically designed to get rid of loopholes and increase transparency in market structures such as the Obligation Warehouse that allow for persistent Failures To Deliver.
This proposal is a great first step to making it more difficult for FTD related fraud and abuse to occur and damage public perception of, and effective engagement with, US capital markets.