Subject: S7-11-23: Webform Comments from Brad D
From: Brad D
Affiliation: Technology Consultant

Sep. 9, 2023

Thank you for the opportunity to comment, as this rule
moves in the right direction to protect household investors. 

Instead of requiring that a carrying broker-dealer comply with the
daily computation requirement for the customer and PAB reserve bank
accounts no later than SIX months after having exceeded the $250
million threshold, it would be much more prudent to change the terms
to THREE months 
for a carrying broker-dealer to make the systems and staffing changes
necessary to perform after it exceeds the $250 million threshold. 

Why? 
An ounce of prevention is better than a pound of a cure. Precautionary
and safeguard measures should already be in place and implemented to
avoid exceeding the threshold to further reduce risk according to the
broker-dealer's own in-house predictive risk models. 

As we've seen all too often, broker-dealers privatize their
gains, while socializing their losses to household investors during
financial meltdowns or other liquidity and credit events.
Unfortunately, this is a feature rather than a bug for most
broker-dealer models, particularly since the Gamestop/Robinhood fiasco
stole billions of profits from millions of household investors in 2021
without any compensation whatsoever as a form of remedy. 

I highly recommend this rule and welcome many more to protect the new
generations of household investors. 

Thank you for your time and consideration,
Brad 

I