Apr. 19, 2022
This seems like granting yet another method for FTDs (Fail to Delivers) to be sanctioned, providing a way to essentially reset the due date, by morphing stock and derivative obligations into a new vehicle (SFT) that are fungible to each other. This seems to allow a party, who cannot deliver on their obligation, a method of buying themselves more time quite cheaply. If this FTD was the result of Short-selling, which is understood to be very risky with unlimited potential for losses on the short side, then this seems to grant them a very inexpensive way to carry their a very risky short position. This spirit of this rule seems to protect the Wall Street / Hedge Funds / Big Banks by providing them with yet another way to game the system at the expense of the retail investor. Our financial system, and the rules that regulate it, are so complex as to not be easily accessible to the average "free market" retail investor. This complexity is an advantage for Wall Street, who crafts these rules, and is a clear disadvantage to the retail investor, who is put at risk when FTDs occur. I do not support this proposed rule. Thank you, Kevin Till