March 3, 2022
Thank you for soliciting comments regarding the settlement cycle. I am extremely frustrated with the concept of delayed settlement in the 2020's. T+2 Settlement may have been necessary in the days of delivering physical shares by horse from Philadelphia to New York... however todays computer systems can transact quadrillions of bits of data nearly instantly from one side of the world to another. Furthermore, advancements in cybersecurity and cryptographic verification allow for verified transactions to take place, and markets can be had with instant settlement.
While moving slowly to a T+1 over the course of several years may seem to be an improvement, it is simply too little too late and not enough to fix the underlying issues within the plumbing of the securities markets. Please work to implement regulations for T+Instant settlement. Anything less allows for abusive Failure-to-Deliver of securities to be cleared through the DTCC's CNS system and end up in the obligations warehouse.