March 12, 2022
As a retail investor I fully support shortening the settlement period for security trades. This is a good start, however there are still large systemic issues with the settlement and clearing pipelines that currently exist that should be addressed. I urge the SEC to consider shortfalls with the CNS system and how maximum effort is exerted by the DTCC and central clearing authorities to mitigate the movement of ownership of securities. Delayed settlement times give malicious intermediaries such as Market Markets and clearing houses ample opportunity manipulate the price of securities. Settlement time should ideally be instant leveraging ledger/blockchain as a source of truth for ownership entitlements.