Oct. 08, 2022
As a concerned retail investor I am violently agreeing with the proposed rule changes. Transaction-by-transaction reporting needs to be the standard. It is a complete joke to think that high speed trading firms executing hundreds of thousands of trades per seconds can't enable transaction-by-transaction reporting or 15 min reporting windows. I have been having nightmares about stock settlement since the DTCC put out a presentation stating that 3% of trades end in FTDs (https://www.dtcc.com/dtcc-connection/articles/2022/august/02/improving-settlement-rates-by-ignoring-them). I have to believe that the lack of transparency in the securities lending markets have at least something to do with this. The proposed rules shine a little bit of light in a very dark place. > Whether the loan will be used to close out a fail to deliver pursuant to Rule 204 of > Regulation SHO or whether the loan is being used to close out a fail to deliver outside > of Regulation SHO. In my opinion, this data _not_ being made publicly available is wrong. It is widely known that the SEC is under-staffed and under-resourced. Open this data to the public to review. The perpetual can kicking of FTDs has to stop. Who will stop it? I personally do not want to work with a broker that has trades that fail-to-deliver or fail-to-receive. If working families knew that they are likely receiving IOUs rather than shares of companies they wouldn't participate in the market. Thanks, -Connor Hindley