Subject: SR-NSCC-2022-003 - Public Comment by Retail Trader
From: Mike Jorgensen
Affiliation:

Apr. 20, 2022

 


To Whom This May Concern, 



As a retail investor I am highly disturbed by the content of this new proposed rule that would effectively allow for Failure To Delivers (FTDs) to continue and worsen, which can be abused by market makers and used in conjunction with naked shorting and dark pool trade routing to control and suppress the price of equities. This does not, in any way, benefit retail investors and is likely to be extremely harmful to the vast majority of those same retail investors that the SEC has sworn to protect. 



Please do not allow Security Financial Transactions to allow new methods of negligence, whereby the financial obligations of the FTDs get passed along instead of settled. This proposed rule is short-sighted in its attempt to create stability and allows for abusive practices where market makers are not held accountable for their failings. This is not acceptable and creates an opportunity to harm retail investors and violates our right to a free and fair market. In order for the equities markets to be fair, market makers must be held accountable for their financial obligations, regardless of the short or long term consequences they face. 



I request that this proposed rule be denied and that similar rules are not proposed in the future, as several similar iterations have already been denied in the past and continue to be rejected by educated investors every time they resurface. The repeated attempts for such a measure to be passed after multiple rejections points to the potential desire for 'loopholes' by market makers and other institutions that stand on the losing-end of the trades they made years ago. ALL trades should be settled within T+1 or sooner in this day and age, and with blockchain-technology there should be no issue identifying, counting, and recording every single share that is currently trading on the market. 



I urge you and your colleagues to reject this proposal and all future iterations of this rule, and to actually stand up for those you have sworn to protect: Retail Investors. The public. Please consider that your decisions on these rules are affecting millions of working-class individuals throughout the United States, and each and every single one of those individuals posses the same right to a free & fair market, as the frauds and manipulators on Wall Street. 



Kind regards, 

Michael Jorgensen