April 20, 2022
Dear SEC Commissioners,
This proposed rule would sanction naked shorting and FTD's to such an extent that our markets would no longer be markets at all. there would be no more zero sum game between buyer's and sellers. The rule would allow the powerful market makers and the privileged few to manipulate markets via naked shorting and face no consequences whatsoever. No bet would be real. No outcome would be determined by actual market forces. We are already facing an egregious amount of market manipulation. This rule would close the coffin on investing by anyone who is not a market maker or hedgefund privvy to the advantage of AI powered HFT. Will the retail investor who loses his life savings be able to engage in \"novation\" to escape the consequences of his trades? NO. Hedge funds and banks shouldn't be able to either. The SEC with this rule change would be incentivizing high risk behavior by \"too big to fail\" institutions and their counter parties off of lit exchanges. It would guarantee explosive growth in derivatives exposure.
What it comes down to is this: The Losers deserve to lose, and the winners deserve to win. Right now the SEC is not doing its job in preserving the simplest of market functions - the outcome of executed trades.