Subject: S7-18-21
From: Mike Miller
Affiliation:

Jan. 04, 2022



To whom it may concern,
 
I believe this new proposed rule is a step in the right direction, however I believe that it is late and too lenient.  Currently, the rules allow for rehypothecation without proper records leading to a multitude of failure to deliver trades.  During the these trades, the pricing mechanism used to lower (or raise) the stock price is artificially manipulated and indeed is not the true price of the stock.  In fact, according the SEC’s data only 0.12% of FTD’s are settled – this inherently means this pricing mechanism is being abused by large institutions.
 
Further, the practice of lending shares without clear notification or direct payment to the individual who purchased those shares amounts to theft of goods.  This practice needs to rectifies if actual price discovery is to be realized.
 
Mike Miller