Subject: File No. S7-05-22
From: Jacy Carroll
Affiliation: Director of Finance, Professor, MBA

February 19, 2022

I support the shortening of the settlement cycle but this proposal does not go nearly far enough. Shortening the cycle to T+1 and only in 2024 is way too far of a runway to close this regulatory loophole. The SEC doesnt seem to be able to enforce with any amount of repercussion to prevent future inaction the current Failure to Delivers of the settlements as it stands. Happy to see the SEC looking into this issue but shortening the settlement cycles does nothing if the punishment is too small and failures to deliver are accepted as normal part of the markets. Investors are losing confidence, myself included, and will move to the blockchain market instead of nothing is done.