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