October 20, 2016
I am strongly opposed to this suggested change. Although for institutions transferring ones and zeroes digitally, the lost day would make no difference, would create no hardship, for those of us who transfer funds from private accounts at one bank or brokerage to another by paper check, the situation is different. I am uncomfortable with untrusted officials/employees 1 at a big brokerage business having information relating to my account(s) at other institutions, and vice versa (as would happen with electronic transfers, which also create a cost to me as the customer, one that I do not pay now).
The previous change of clearing period from a week to 3 days was bad enough to go to 2 days is unrealistic and a burden to retail investors like me who do not have a staff, do not have bank-level security on home or office computers, who actually mail checks and drive cash from one bank to another.
I am not a participant in the digital-currency world: I pay many bills by paper checks, do NOT use direct deposit, and use cash for almost all of my day-to-day expenses, as I do not want to have 3% skimmed from every transaction by debit or credit card. There is no urgent reason for me to get my money a day faster after a stock sale—in fact, I note that it seems that my broker does not seem to be consistent in the length of time that pending transactions take to settle: a recent pending credit to my account seemed to take longer than the expected 3 days (not sure of that, did not document it, but I did call about it when it seemed to be pending longer than it should have been). I do NOT consent.
Regarding liquidity, I note that after the 2008 debacle, there were complaints about the casino atmosphere, the computerized high-volume trading that destabilized the market. We would do better to slow things down, to require brokers and market makers to have higher liquidity requirements, not facilitate the churn with shorter settlement periods. Having to hold extra in reserve for an additional 24 hours—rather, NOT allowing the reserve to be released 24 hours early, will be helpful to retail investors who hold long-term positions.
Instead of lowering barriers to stock ownership for the general public, this is another way of giving advantage to the financial industry and professional traders. I do NOT consent.
As an aside, the ONLY reason I found out about this proposal is that I had missed hearing about the tick pilot program that affected my ability to set prices for some of my trades at the level I wanted—the prices are now in nickel increments. I was notified of this by my broker last week—when I investigated, I found that the public comment period had ended on Oct. 6. It would be helpful to require brokers to notify clients of pending SEC policy changes that will affect them BEFORE the public-comment period closes? For that matter, how do you solicit public comment? What e-mail list should I join, what Web site should I bookmark, who do I call? (Ghostbusters?)
1Not that I am suggesting that any of these people are not carefully vetted upon hiring, that they are in any way individually or collectively untrustworthy, but they are strangers to me and I do not willinglly and easily share my personl, private confidential information with people whom I do not know and/or with whom I do not have a personal business relationship.