July 18, 2023
Dear Ms. Countryman,
I applaud the SEC's effort to increase the computation frequency of Broker-Dealer Reserve Requirements under the Broker-Dealer Customer Protection Rule from weekly to daily and I support this rule.
Please allow me to suggest increasing the frequency to real-time, i.e. a computation every second.
High-frequency trading and algorithmic trading occurs at high speeds, often in milliseconds or microseconds - a millisecond is a thousandth of a second and a microsecond is a thousandth of a millisecond
In fact, the technical prerequisites for such complex computational operations are already present and in place and should not be burdensome to broker-dealers.
Besides the real-time computation of Broker-Dealer Reserve Requirements under the Broker-Dealer Customer Protection Rule, I suggest a very transparent electronic publication of whether said requirements have been met or breached.
This should make available for customers an unprecedented level of insight and transparency that would allow to make instantaneous investment decisions and that would allow for efficiently allocating capital in a free, orderly and efficient market.
Sincerely,
J. Santos