Subject: File No. S7-05-22
From: Matthew Clemens
Affiliation: COO, Azimuth Media

February 18, 2022

Settlement should be within an hour. In this electronic era, I can buy a game on Steam or a movie on Amazon, or my lunch on Doordash and have it within the hour. I can get physical objects delivered in a shorter period of time than the settlement period proposed.

Does it take an ATM two days to provide my funds?

My recommendation is that all transactions are T+0 delivered to the SEC as the intermediary. The SEC then completes the transactions by forwarding both sides of the exchange to the designated recipient and publishing anonymous market data based on the exchange.

The real data can then be held on SEC(ure) servers and analyzed for things like wash trades and FTDs. Mandating that even ATS transactions register would also ensure 100% of trades get printed and remove an unfair information advantage some firms have over retail without invalidating the exchanges ability to sell it (assuming SEC info was delayed until the end of the day, for instance).

Stocks should transact as quickly as money wires and the public knows it. Two half-hearted measures makes four times the headache. And given the public is 1) infuriated by COVID restrictions, 2) spending their extra time reading up on the market, and 3) can no longer be talked down, I would recommend giving them what they expect.

Just my two cents so you can skip the T+0 push next year. Can even provide a general framework for how the system could function.