Subject: S7-26-22 Open-End Fund Liquidity Risk Management Programs and Swing Pricing Form N-PORT Reporting
From: Henning Klimaczewski
Affiliation:

Nov. 10, 2022

 

Dear Madam or Sir, 




I thank you for the opportunity to be heard by an institution like yourself. Please allow me to lay out my points of interest and concern in the following paragraphs. 


I fully support the hard closing of shorts that violate liquidity requirements, and also support the forced buy-in of any and all fails to deliver (FTDs) on shares that have not been located. 


Furthermore, if a FTD occurs on any given stock, which amounts to the fact that the borrower of shares has, for whatever reason, zero (0) liquidity on said stock, short selling must be prohibited up to the point of the borrower proving reliably, that he has acquired new liquidity to even out any open FTDs. 


I am sure working through all the comments you are getting as of late is very exhausting and I personally want to thank you and all your colleagues for taking your time to dissect every statement and prepare a list of points, prioritized by the number of comments regarding the same context. Ultimately, as things have been going for quite some time now, it is crystal clear that the current market situation is neither fair, nor free. At least for the typical retail or small-time institutional investor. Especially huge Insitutionals who are also posing as market makers (MMs) in the financial world are, unfortunately, extremely prone to mismanagement of their investor's money, including outright fraud in what they are doing within the market to maximize their gains on the shoulders of almost everybody else. 






Thank you and have a great day, 
sincerely, 


Henning Klimaczewski 
Retail investor 
Germany