Subject: SR-NCSS-2022-003
From: James G.
Affiliation:

Apr. 20, 2022



To whom it may concern,

As an international investor I find the proposed rule to be deeply disturbing. This would allow FTDs to continue their unsustainable trajectory and worsen. Market makers can ‘further’ abuse this alongside financial malpractice in naked shorting and dark pool abuses of retail orders destroying price discovery. These processes are already being used to suppress prices and route genuine retail orders through dark pools by market makers with incentives to take the opposing position. This is non-beneficial to the US ‘free-market economy’ and its participants in its entirety except for a select few. Isn’t the SEC supposed to protect investors? This appears to be a complete shirking of that duty. FTD’s should be settled by those who are trying to pass them on. This seems like a short-sighted and uninformed move by the SEC, if not outright negligence. Those taking the other sides of trades resulting in FTDs should be told to settle them as opposed to kicking the can further down the road. The current actions and proposed rule change by the SEC  imply that this is not a free and fair market and that they are doing the opposite of protecting retail investors, instead, violating their rights. Remove the proposed rule change and do not propose anything similar in the future, this should be abundantly clear by past iterations that have been rejected by investors previously. What is the SEC…or should I say why is the SEC proposing such a rule that has had no support from educated investors in all prior proposals? The SEC is there to protect investors, all investors, not the ones who are in trouble on their trades and are failing to meet their obligations in the form of FTDs. Market makers subverting the free market and actively stealing from other investors seems like a more important goal from the SEC. I will say as a UK investor in the US market I am outright shocked at the failings of the SEC at its fundamental purpose for its being. I hope this is rectified soon.

Thank you for your attention.

Regards,
James Gribben