Apr. 20, 2022
This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be very risky business practice. This rule flies in the face of fair market mechanics, and gives unlimited power and scope to bad actors who would abuse such mechanics. It is set in place to "alleviate Fail To Delivers", but in action does nothing to eliminate them, and in effect protects the action of naked short selling, which is ALREADY ILLEGAL. This rule leverages the complexity of financial vehicles to put power in the hands of institutions, effectively safe-guarding them from their own bad bets. Passing this new rule would only further deteriorate the American public's faith in a "free and fair market". I urge you to withdraw this proposal immediately. FTDs are already "reset" through a variety of methods such as using deriviatives not allowing them to reach their 30 day mark where the security needs to be "delivered." This is very frustrating to see rules like this being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years.