Subject: S7-21-22: WebForm Comments from Andres Loubriel
From: Andres Loubriel
Affiliation:

Aug. 12, 2022



August 12, 2022

 Thank you for allowing me the chance to submit comments on this proposed rule.

It is my perspective that clearing houses like the DTCC have proven countless times to have inherent conflicts of interest and need to be regulated more.

In my mind, claims from opponents of this proposed rule citing clearing houses requiring flexibility to operate and therefore should not be regulated are excuses to continue operating in the dark.

There is a prevailing issue in our markets when it comes FTDs (Failure-to-Delivers). This proposed rule I believe is a good step in reducing FTDs to shine light on what is going with stock certificates managed by clearing houses.

How any market can tout itself as reliable while having routine FAILURE-TO-DELIVERs on goods purchased with real money is ridiculous in my opinion.