Apr. 20, 2022
I want to send a quick note in opposition to this newly proposed rule, though it would seem the rule has previously been proposed and then scuttled due to vocal pushback on it, so I am not sure why the ideas in this current proposal have resurfaced. If it was not a welcome rule before it is not now. The reasons why have not changed, the rule will help facilitate the deferment of dealing with FTD’s in a timely manner, and help in naked short selling, a practice that does NOT help investors. I continue to be disappointed by the lack of action being taken by the SEC to protect me as an investor, instead I am not sure what the SEC’s role really is, since it would seem that so many of the rules passed over the preceding year have not been enforced. I am not a market expert, yet even I can watch the market right now and see odd behaviour, such as so much of the retail investor orders being routed through dark pools where they do not affect price discovery, or the insane levels of short interest on more than a few stocks. The overleveraging of assets on the market right now is a massive threat to global economic stability and I feel the SEC is not doing its job to keep things in check. Failures To Deliver should not even be an acceptable practice in the 21st century and the technologies we have. Yet here we are and these things are commonplace. Instead of repeatedly trying to pass rules that will allow for the continuance of these practices, perhaps the SEC should start to do their job and clamp down on institutions that are bending or breaking rules with impunity. The amounts of your fines are a joke, your payments to whistleblowers feel more like “hush money” than anything that will lead to more fair markets. Things need to change, and you can start by cancelling rule SR-NSCC-2022-003, and not trying to resurrect it in a new form yet again. Thank you for your time. --- Jason C. Ross Operations Manager / GIS Analyst Silvacare Inc. Unit 4 145-19th Street Courtenay, BC, Canada V9N 9G2 Telephone: 250.999.8965 Workdays: Tuesday to Friday