Feb. 04, 2022
To whom it may concern, You were requesting public comments on Filing S7-32-10 to which, predominantly I am completely FOR. There has been market manipulation for far too long, and in my opinion this kind of ruling is long overdue. There would be only one change I would recommend which may be outside the scope of this filing, which is related to fines and punishment for those violating the rules; Currently fines are simply a ‘cost of doing business’. The problem with this then is the cost of fines are simply built into the monetary model, and are accepted without any real consequence. My proposition is: A) If a rule is broken, any gains and or profits that have been accumulated as a result of the rule-breaking should be taken back from the fund/company that broke that rule, and then are fined for breaking the rule(s). B) If a similar rule is broken repeatedly, then the function of that business is then suspended for a duration of time. Banks, Hedge Funds, Market operators and so-on seem to be regulating themselves, and so no real punitive measures are taken. That is a significant change that would be useful/necessary. Finally, it seems the majority of these rules in the Filing S7-32-10 seem to be around transparency which I believe is a fundamental first step into proper enforcement and regulation which I support. The current reality of the market is such that there is no correct price discovery. The majority of retail trades are directed through unlit exchanges which do not affect stock price. This completely circumvents the fundamentals of economics: Supply and Demand. By altering the appearance of demand, you control the price. I.e.; The price is incorrect. Adding a lack of enforcement self-regulating agencies, and you have a system seemingly designed to make money for only those who control it or have advance information unavailable to the public. Overall, I support all rules that: A) Promote fairness for all parties. B) Promote transparency of information for all parties. C) Regulate agencies that are clearly incapable of regulating themselves. D) Promote and support a system of fairness, equality, and quickly-available information. E) Promote fair, swift, and just punishment to any who intentionally, willingly, or repeatedly break rules or circumvent (find loopholes) processes that allow for unfair advantage. F) Prevent conflict of interest* *There are a few examples, but a Market Maker who is simultaneously a Hedge Fund, to me, seems like an egregious example of conflict of interest. Similarly, congress members who have access to insider trading information should not be allowed to trade stock, though this is certainly outside the scope of this document. I have hope for a system that is actually fair and while the current markets are clearly not that, I do believe it is achievable and File Number S7-32-10 is a good step towards exactly that. Thank you for your time. Sincerely, Dave Champagne