Subject: Comment For Release No. 34-93391, File No. 265-33
From: Samuel Johnson
Affiliation:

Oct. 25, 2021


To whom it may concern,

The current stock market is currently being dominated by rampant abuse, leading to an existential crisis of the United States itself. There are numerous things that are leading to this, including decades of complicity by regulating organizations and complacency of the people and these organizations. The wealth gap between rich and poor is growing each year and we are only getting worse while the top 1% slowly scalp more and more money from the bottom 99%. 
Based on the data that has been discovered over the last year, as a retail investor, I have almost zero faith in the capital markets as they currently stand. We need an entire overhaul of the system, and we need it fast before it leads to the collapse of the financial system. 

I am extremely concerned about the following issues and would like to have rules put in place immediately to combat these concerns before it is too late. 

1. The lack of transparency around short selling. All short sales should be reportable to the SEC. All institutions should be required to submit every order to a central location so that all security transactions are fully traceable. 

2. Hiding of FTDs using derivatives and regulatory loopholes. Transactions that result in an FTD should be REVERSED completely and repeat offenders should NOT be able to participate in the market. Fines must be multiples of the revenue gained when the rules are broken. If they made 1 billion USD by breaking a rule, they should be fined 3 billion. The fine must match the crime! It must not be a slap on the wrist! 

3. Rehypothecation of short sales allow for an infinite about of short interest masking the true value of the stock. Rehypothecation should be banned. All securities should be serialized so that they cannot be rehypothecated. They must be non-fungible. 

4. Abusive Naked Shorting must be outlawed with hefty fines and criminal charges. The capability to naked short by MM should be completely removed, and audits of software should be completed to ensure it is not happening. Liquidity does not trump market manipulation - meaning I would rather have less liquidity than have rampant manipulation in the market. 

5. Conflicts of interest through things such as insider trading and revolving door careers. 

6. PFOF should be banned as it slowly steals from retail and has a direct impact on the buy/ask spread and price discovery. 

7. Oversight of market makers is needed to ensure MM capabilities are not abused. 

8. Organizations should not be allowed to rampantly abuse the capability to internalize orders and use dark pools. Any use of dark pools should be authorized by a regulating agency prior to the sale. 

9. Any organization that is too big to fail should be split up so that the American government does not need to bail out any company if they go under 

10. High Frequency Trading should be banned as it only benefits wall street by scaling retail pennies at a time. The market should be optimized for providing capital for companies to succeed. Long-term holding should be incentivized, and high frequency trading should be drastically dis-incentivized. For example: Ultra-short term taxes of 99% for trades less than 5 minutes. There is RARELY a need to buy and sell the same shares at a frequency less than MINUTES. 

11. Self-regulating organization should not be assumed to be self-regulating. 

Thank you for taking the time to read this. I appreciate your concern for our capital markets. 




Best regards, 

Sam 




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