The following Letter Type A, or variations thereof, was submitted by individuals or entities.

Letter Type A:

Dear SEC, 

As a household investor, I am writing to express general support for the NSCC’s proposed rule change, outlined in SR-NSCC-2024-007, which aims to update rules to better accommodate transactions from fractional share trading programs. 

I believe that the introduction of an exception to the Real-time Trade Submission Requirement for Correspondent Clearing transactions representing aggregated transactions of fractional shares is an interesting step forward in adapting to the evolving needs of individual household investors like myself. 

It is my understanding that fractional shares not being part of this system might mean these trades are less liquid compared to full share trades, potentially resulting in less favorable execution conditions such as wider bid-ask spreads and hampered efficiency that can slow down execution and settlement times. 

This change recognizes the unique nature of fractional shares trading and the importance of reporting them quickly for prompt and accurate clearance and settlement. 

However, I would like to suggest a modification in the language used in the proposed rule change. The current wording, "should be submitted as promptly as reasonably practical," may allow for unnecessary delays. Changing this wording to "must be submitted as promptly as reasonably practical" would reinforce the importance of timeliness and accountability in the submission process. 

Additionally, I am pleased to see that transactions from fractional share trading programs will be subject to the same margining and risk management practices as other equity transactions upon trade recording and validation by NSCC as this should help lessen counterparty exposure concerns and protect the clearing houses so that they aren't tempted to attempt turning off the the buy button off from retail, again.


Thank you,


A concerned retail investor.