Subject: File No. S7-05-22
From: Jeremy
Affiliation: Engineer

March 9, 2022

I believe that T+0 is a necessity for modern stock trading. While cryptocurrency transactions can be concluded in a manner of minutes and domestic wire transfers can be concluded within the same day, there is no reason that the stock market cannot follow suit with same day settlement. This kind of accelerated transaction fulfillment would fall well within the mission statement of the Depository Trust Clearing Corporation (DTCC) and their purpose of expediting and automating capital markets. And given that High Frequency Trading firms can move stocks and funds around in nanoseconds, the market already has the infrastructure for quick communication and transactions. There just needs to be the driving motivation, or regulation, to implement it.

If I have any criticism about the plan, I would say that taking 2 years to implement T+0 is far too conservative. When the market participants are exploring the means of obtaining T+1, they should already have T+0 in sight as the overall goal. Therefore, the time from T+1 to T+0 should be significantly shorter than T+2 to T+1. I would suggest 6 months to go from T+2 to T+1 and 3 months for T+1 to T+0 with final implementation at year end. If I were given a software optimization project and it took me over in 12 months to finish it, I would be fired. I see no reason to grant such excessive leniency for an industry that has had computerized automation since 1966 (NYSE).