Apr. 20, 2022
To those positioned to vote on this proposed rule: I am a former Financial Planner for what was American Express Financial Advisors that eventually spun off to Ameriprise. I held Series 7 and many other series and insurance licenses that helped clients learn to invest for their futures using the assets available in the post dot-com bubble bursting. I’m well versed in market strategies, book and market valuations, intrinsic values, FA and TA, and most importantly to this rule, the obligations inherent in the risk assessment of investing. I cannot understand how this rule works for the benefit of all investors. It is instead written to protect the very institutions that assessed the risks of a trade and resulted in obligations that must be met. As a retail investor, we don’t get to delay our obligations through contract novation. While the underlying obligation doesn’t go away legally through this process, it does stall. And that time might be indefinite. In no way is this equitable for all investors. This rule should be withdrawn from consideration immediately. I’m disenfranchised with the condition of our US equity and derivative markets. I’m not an expert in commodities but I suspect they are no different. I admit I was naïve when studying and certifying to help clients in thinking that the market is free and all these factors impacting supply and demand result in price settlement, but I’ve participated, studied, and learned. This marketplace has proven over and over that there are those that are “too big to fail” and clearly can get rule proposals like this put in for consideration to benefit themselves. I am terribly disappointed that more and more the market is proven to be manipulated in favor of these institutions. I’ve decreased my participation in the market to seek out other ways to earn returns elsewhere, and I’m sure I’m not alone. Please restore trust in our markets as a citizen and “retail” investor. This email likely won’t make a difference, but for the sake of my children and their future, I hope it is one drop in a tidal wave of other drops demanding we stop allowing market “makers” to fix the outcomes of trades. We all want a chance to better our outcomes, but if those market makers, brokers, and short sellers disproportionately offset their obligations compared to retail, it’s not because they are smarter or more sophisticated; it’s because rules like these allow them. Give us a market we can be proud of. You have an opportunity to be a part of sweeping reform and remembered forever Please don’t be like your predecessors who so often are seat warmers until inevitably taking a job at one of the market makers or hedge funds they are supposed to be overseeing. I could write for days about what I have experienced firsthand and what I have researched, but I’ll end this here. Please do not consider this rule for vote and reject future attempts to tip the balance of the retail vs institutional investor further than it already is towards institutions, and work towards tipping it back. Respectfully, A Concerned Citizen