Subject: S7-31-22: WebForm Comments from Michelle Ball
From: Michelle Ball
Affiliation:

Feb. 22, 2023

February 22, 2023

 Dear Securities and Exchange Commission,

I am writing to you on behalf of the investors with a request that we believe is not an outrageous one. We would like to see mandatory buy-ins for all Fails-to-Deliver (FTD). When we purchase something, we expect to own it, and we do not think that this is an unreasonable request. We do not need order-by-order competition, and we are happy for Payment for Order Flow (PFOF) to continue if, and only if, FTDs have mandatory buy-ins and strict enforcement penalties.

We understand that Wall Street wants to keep all the practices and rules they have invented. We agree that PFOF and 0 disclosures for short sales are important for the markets. We are happy for these practices to continue, and we do not want to change them.

However, we do request that in today's world of technology, FTDs should not be allowed. When we buy something from Amazon, failure to deliver results in an instant refund, and it is very clear that the delivery has failed. It is intuitive and straightforward. FTDs make no sense in today's world, and they should not be allowed.

We acknowledge that this might cause some temporary stress to the markets, but only for the participants who were failing to deliver. We believe that businesses that fail to deliver are not businesses but are merely Ponzi schemes.

Therefore, we propose a fair compromise. Wall Street can keep everything they want, and in return, we ask that all FTDs be bought in or clearly marked. We suggest that the Internal Revenue Service (IRS) audit these transactions to ensure that participants who fail to deliver are penalized, and any fines collected should be given to the American people. We do not think this is unreasonable, given that these businesses were failing to deliver on their only job.

We do not believe that we need Depository Trust Company's Direct Registration System (DRS). DRS is just a roundabout way of forcing delivery. Our request is simple and not outrageous. We are letting Wall Street keep everything else, and we are only asking for FTDs and any equivalent concept to be marked as illegal and fraudulent, just like any other business on the planet. We believe this is a straightforward request that will benefit all investors.

Thank you for your attention to this matter.

Sincerely,
Mike Ball