Apr. 20, 2022
Dear SEC, This is nothing more than another attempt to game the system by writing vague unenforceable rules that allow large players to manipulate the system to their advantage. In what other industry would allowing someone to pretend to sell you something only to intentionally replace it with whatever they deem of equal value be allowed without the buyer approval? Let’s ignore the thousands of other methods they are using to screw investors out of their money. Approving this would write a blank check to firms to do whatever they want simply by saying they believed the stock you specifically purchased was equivalent to whatever they picked. They could take your $1,000 investment and exchange it for the $10 Blockbuster gift card you have had sitting in your wallet for the past 20 years and you would give them a pass as long as the firm said it was equivalent in value. This is nothing more than handing out hundreds of millions of get out of jail free cards and telling them they can do anything they want to avoid being held accountable for their excessive risk and poor decision making. If this were done by an individual investor, they would spend the rest of their lives in jail. Unfortunately, because you are bought and paid for, you allow this garbage to be discussed and often approved. Grow a pair and do your job (it’s time to start protecting the retail investor and holding firms accountable for their fraud). Until you are actively enforcing all existing rules on a transaction-by-transaction basis you should automatically reject every request that comes across your desk. The only exception to that would be if a proposal is written to specifically remove one of the thousands of ways to avoid disclosure and accountability. Every single position of every single firm should be disclosed without exception. Any attempt to alter a transaction without the express written consent of the buyer should be prosecuted as fraud and should result in the immediate termination of the associated firms trading license. Sincerely, Jesse