Subject: File No. S7-22-16
From: Gene Finn
Affiliation: Retired Former Chief Economist (1969-1976)

December 21, 2016

Re S7 22-16

Cash Account Individual customer transactions should be excluded from T+2 and settled on a COD basis like institutional transactions.

Brokers require securities and cash or their equivalent to be available in the account for transactions to occur. Hence customer is already being held to COD terms to be met before the trade.

Why delay net settlement of principal trades beyond trade date?

Let market makers compete for order flow including quickness of settlement and securities and cash custodial services.

Respectfully yours,

Gene Finn