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 FTD’s (Failure To Deliver) to not only continue, but worsen. This 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 falls under the heading of “underhanded & shady practices” and does not in any way benefit retail investors. Please do not allow SFTs (Security Financial Transactions) proposed in this rule to create new and potentially endless layers of FTDs to be allowed, whereby the very real financial obligations of the FTDs get passed along instead of settled. This will allow for abusive practices where the market makers are not never held accountable for their failings. This is unacceptable and creates an opportunity to negatively impact retail investors and it violates our rights for a free and fair market. This rule is proposed solely for the purpose of avoiding true price discovery through the practice of onward lending. It removes the risk of naked short selling by giving the short seller an obvious unfair advantage of perpetually rolling over their short position. This rule will undoubtedly have negative affects to the retail investor. Moreover, if passed, an unintended negative outcome will be that international investors will stay clear of US markets for this lack of transparency. I respectfully request that this proposed rule be removed and not brought up again in any form. Please do not try to propose this or something similar again as some form of this rule has been rejected in the past and continues to be rejected by educated investors every time they resurface. The mission of the SEC is to look out for the well being of investors. As such I propose that you direct your attention to doing so. Sincerely, Chris D'Viccho