Subject: S7-31-22: WebForm Comments from Brandon G
From: Brandon G
Affiliation:

Feb. 23, 2023

February 23, 2023

 Good Evenings,

I am in favor of this proposal but I do not think this goes far enough to protect retail investors. Retail investors should not have their orders routed to a small group of off-exchange dealers for any reason. All orders should be routed to the lit exchange and have an impact on the price. These off exchange dealers or dark pools are being abused by those wholesalers and market makers to limit price discovery from retail orders and creates a conflict of interest and  allows for these market makers to perform market arbitrage.

The current state of the market allows for failure to delivers, naked short selling and abuse via swaps. We need to provide a fair and free market for everyone not just the rich and powerful. On some securities market makers and wholesalers work together and sell a security and then fail to deliver said security when they could easily go and buy it from the lit market to deliver the share but have decided that buying said security from the lit exchange would not be in their best interests while it would benefit the buyer of the security as the price would rise. They do not and simply mark it as a fail to deliver which should have harsh penalties. The penalties for a failure to deliver should include a $1000 fine for each share to the buyer of the security and to the government. This would fix the market problem. You should not be able to sell something that you do not own or have no intention of buying to sell. Fail to delivers, short selling or bona-fide market making is what is cau
 sing a problem in our markets and we need strong laws that prevent the market makers, and wholesalers from abusing their power.

Thank You,
Brandon