Mar. 5, 2023
TO: David Bottom, Director/Chief Information Officer, Securities and Exchange Commission, c/o John Pezzullo RE: Comment on Rule Rule 8c-1 Mr. Bottom, I am a household Investor and am writing to make a comment on Rule 8c-1. Rule 8c-1 generally prohibits a broker-dealer from using its customers' securities as collateral to finance its own trading, speculating, or underwriting transactions. More specifically, Rule 8c-1 states three main principles: (1) a broker-dealer is prohibited from commingling the securities of different customers as collateral for a loan without the consent of each customer; (2) a broker-dealer cannot commingle customers' securities with its own securities under the same pledge; and (3) a broker-dealer can only pledge its customers' securities to the extent that customers are in debt to the broker-dealer. Additionally, Rule 8c-1 requires broker-dealers to make certain written notifications to pledgees in connection with such use of customer securities as collateral. I am in full support of rule 8c-1, and am frankly, SHOCKED that this common sense protection for Household Investors is not already in place. Broker-Dealers have no business using their clients assets for ANY purpose whatsoever without specific and individual consent. Sincerely, Michael Gilbert