October 16, 2021
Id like to voice several of my concerns about this proposed rule change (7.13) as written.
1. The wording of the rule is vague and overreaching, allowing a ticker to be suspended based solely on the opinion of one/several individuals. There is no metric for or standard written as to how or when a halt would be invoked. At the very least, it needs to be rewritten with more specifics as to the standard that would be required, and the opinion of the chairman absolutely needs to be left out of the equation. The market and the American economy/financial system is the gold standard for the rest of the world, and enacting such a broad rule with no metric or standard by which it would be enacted allows for unbridled corruption, which would absolutely cause more faith to be lost in our free and fair market and cause damage our financial system.
2. In this rule, it is also stated that off-exchange trades would not be suspended. Very few have access to off-exchange trading pools, and as far as I know, NO retail traders have access, so this leaves millions of investors with no ability to trade, should the rule be invoked on a stock. This has the potential to directly harm investors and also the companies listed on the exchange. If trading is only halted on the lit exchange, but allowed to occur on the dark exchanges, institutions and hedge funds receive yet another very imbalanced advantage. If trading is halted, it should be halted across the board, or not halted at all.
3. There is at least one alleged instance of an egregious conflict of interest. As explained by another concerned investor in a previous comment, per this rule, the chairman of the NYSE would have the authority to halt trading for two days. The present chairmans wife has a charity which has allegedly been accepting sizable donations from Ken Griffin and his market maker known as Citadel. Citadel and Ken Griffin are currently under investigation by the SEC for coordinating with brokers to prevent trading of certain securities. This purported relationship between the NYSE and Citadel/Ken Griffin at such a time as this rule being introduced raises a lot of red flags.
I understand that suspension of trading is not a new idea, and can be beneficial to maintaining a healthy market. However, in my understanding, the current rules of the NYSE already allow for halts/suspensions. This rule seems to be proposed in order to allow the opinion of the chairman and/or the board to make the decision, and it is my strong belief that our markets and exchanges require a more impartial standard.
I appreciate your time and consideration, and strongly urge you to reject this rule as written.