October 16, 2021
I am greatly opposed to SR-NYSE-2021-60. Given the nature of OTC trading such as darkpools and other forms of unlisted trading, if the purpose of this rule is to prevent fraud... that's the market that needs to be paused. If you halt trading on the lit exchanges, where the data can be viewed and assessed, but not the OTC market, then you are likely missing the fraud.
What better way to commit fraud than on markets with reduced transparency and fewer regulations? Additionally, this rule would be working against retail's best interests and further benefiting the market makers and similar groups that profit off of these OTC trades. If halting of trading is necessary, let ALL trading be halted. The proposed rule has significant shortcomings and potentially helps the perpetrators of the same fraud it is trying to prevent.
Unlisted trades are currently generating significant concern among retail investors. The frequent fines that banks and other large trading organizations receive go to prove that unlisted trades are filled with fraud. This is leading to reduced faith in our system... both with retail investors as well as foreign investors. SR-NYSE-2021-60 would be another step that proves our financial market is made to benefit particular groups... of which retail is not a part of. We need more transparency and less OTC trading. If we continue down this path, the inevitable outcome will be disenfranchisement of a large population after they lose faith in the markets and the regulating bodies that have proven ineffective at fairly regulating them.