Subject: 10-239: WebForm Comments from Raiphe Kelsch
From: Raiphe Kelsch
Affiliation: Raiphe Kelsch

Feb. 28, 2023

February 28, 2023

 Aside from allowing continuous trading 24/7 to institutions only, this will be detrimental to the integrity of the system.  This process will produce more FTDs (Failure To Deliver) -- which are an archaic remnant left from the days of paper trading.  FTDs should not be allowed at all with todays technology.

When these institutions can show that they are behaving legally without fraud, manipulation, dilution of shares, etc. . . then perhaps we can support access to Dark Pools.  These institutions have been manipulating the market for decades and they simply receive a slap on the hand.  What does it take for crooks like Madoff, Kenneth C. Griffin, and Steve Cohen to lose access to the markets?  How much fraud is permissible as 'cost of business'?

This needs to end, or at very least nothing 'new', before there's is a catastrophic collapse in the unregulated derivatives markets.  These Darkpools are only exacerbating the problem.