Subject: S7-01-23: WebForm Comments from Jon C
From: Jon C
Affiliation:

Mar. 15, 2023

March 15, 2023

 The rule as it was originally proposed closed loopholes that were in dire need of closing. To propose the rule with an exemption for those who cause the most damage and who profit the most from exploiting it does nothing to protect individual household investors and only tips balance ever further in favour of those who profit from price manipulation, through naked shorting and abuse of the ability to counterfeit shares on an industrial scale in the name of  providing liquidity, and functions to prevent any hope of accurate price discovery based on supply and demand.

Quite simply it should be illegal to sell stock without owning it or ever having to close the resulting short position through abusing ftd cycles, and the opacity of the dtcc to dilute the floats of companies and stealing value from other investors with impunity.

There should be no exemption for market makers or hedge funds, least of all those who are repeatedly and routinely fined (in disproportionately small amounts compared to the profits made from breaking those rules - making such trivial amounts a negligible cost of doing business illegally and unethically) all without any meaningful disincentive, or penalty or any requirement to admit guilt - often years after the offence and without compensating those who are harmed.

To water down the rule and exempt those who abuse their positions as market makers to manipulate the markets in their own favour creating an unfair advantage, is a betrayal of all other market participants and hands the foxes the keys to the hen house.

The rule should have been implemented without those exemptions, and still should be.