February 22, 2022
Hello,
T+1 by 3/31/24 falls short of making meaningful change in an antiquated system. In the spirit of transparency in our financial markets, all stakeholders ought to strive for real-time settlement (T=0). No cycle is necessary -- and this absolutely, 100% can be accomplished with technology that is already available and widely understood to be safe and reliable (see: blockchain). Anything other than T=0 settlement cycle fails to address the pervasive issues which Dr. Susanne Trimbath calls the \"Triumvirate of Trouble.\" That is to say, without a real-time locating and settlement system in place, retail investors, small corporate issuers and the American economy as a whole will continue suffering the consequences of heedless naked shorting, loaning of borrowed shares, and failures to deliver. What are you doing to prevent September 2008 from happening again? Are taxpayers going to bail out the bad actors again? Do you believe this is a sustainable situation?
T+1 by 3/31/24 is not nearly good enough, and will be too little, too late by the time it has come into existence.
Thank you for taking the time to read this.