Apr. 20, 2022
To whom it May Concern: As a retail investor, I am highly disturbed by the content of this new proposed rule that would effectively allow for FTDs (Failure To Deliver) to continue and worsen, which can be abused by market makers and used in conjunction with illegal naked shorting and abusive dark pool trade routing to control and suppress the price on security trading. This does not in any way benefit investors and in fact could be extremely harmful, which is anathema to the entire purpose of the SECs very existence. Please do not allow SFTs (Security Financial Transactions) proposed in this rule, to create new and potentially endless layers of can-kicking to be allowed, whereby the very real financial obligations of the FTDs get passed along instead of settled. I can see how it provides stability in the moment, but it also allows for abusive practices where market makers are never accountable for their failings. This is not acceptable and creates an opportunity to harm retail investors and it violates our rights for a free and fair market. The manipulation needs to come to an end. It is unbelievable to me that a rule like this is even proposed. It is not a 'rule'. It is a loophole. It appears to be specifically drafted in order to allow bad actors in the market (illegal naked shorting & failures-to-deliver) to have yet another loophole in order to continue their illegal practices. It is always in the name of liquidity. Investors don't mind poor liquidity. If a security's bid/ask spread is large and there is a stalemate in the market - so be it. We can wait. I have read through many of these rules and have yet to find one that plainly benefits retail investors. It saddens me that the SEC, which was created to protect the integrity of markets and retail investors, increasingly appears to be abusing its power to do the exact opposite of what it was created to do. We are losing faith. Shame on whoever approved this 'rule' to be considered for implementation. Sincerely, Jacob Cagle