Apr. 20, 2022
To the honorable members of the SEC and NSCC: I, a concerned retail investor, am greatly unnerved by this new proposed rule. It appears to allow for Failures to Deliver (hereafter FTD), to be passed along indefinitely. While some FTD is to be expected while liquidity is being provided to the market, this rule can be easily be abused by market makers. When combined with Naked Shorting (an illegal practice that I'm sure the SEC and NSCC are aware occurs, and actively work on stamping out), and the internalization and/or abusive routing of retail orders through Dark Pools for price suppression (which I am also sure the SEC and NSCC are aware of, and actively attempting to limit the use of Dark Pools to ONLY large institutional orders as was the intent of their creation), this proposed rule will allow for indefinite FTD extension. This extension will only encourage such malevolent and anti-market behaviors such as naked short selling and "cellar boxing". This will not benefit investors in any way, but instead, appears to be extremely harmful, contrary to the mission of the SEC and NSCC. Please stop this and any future similar rules proposing Security Financial Transactions (hereafter SFT) from coming into force. This rule, and any like it, will only create an endless cycle of FTD which will never be paid, removing the risk of shorting, encouraging naked shorting, leading to the downfall of the entire market. Given that this is a "Market", any entity participating in it takes on risk and liabilities. Those holding short positions must be held accountable to their financial obligations. If they are not, and the aforementioned abusive practices are aided and abetted, then the entire world will lose faith in the American Stock Market, and collectively remove their funding from our systems, causing a financial calamity on a level never seen before. Similar rules have been proposed in the past, and they have all been struck down. Please, strike this one down too, and prevent any such ideas from ever coming so far as to be proposed as a rule ever again. This is for the sake of all investors, institutional, governmental, and retail.