Aug. 12, 2022
August 12, 2022 As a Canadian investor with investments in US companies, and directly impacted by actions of the registered Depository Trust Company, I urge the SEC to pass this rule with no amendments or exceptions to members. The past several years have been increasingly concerning as both a retail investor and a Canadian citizen. Other comments from members registered with the SEC are also concerning, as I do not see why they would be so against this rule (which is worded to allow the SEC to effectively regulate its members) if they are not already committing various actions that would become punishable under these new rules. Protecting against conflicts of interests, particularly driven by the leadership and board of these member clearing agencies, is a fantastic rule. Not only will this protect the end-user retail investment clients of the SEC's registered members, but it protects the members themselves and allows them to protect their businesses from bad actors who would leverage their conflicts of interest for personal gain. I am relieved and encouraged by this rule and hope to see it passed with no amendments and no accomodations for registered clearing agencies. One hope I have for the SEC is to not allow itself, as a regulatory body, to be less authoritative or able to enforce its rules than its members' ability to break them. Should this rule not pass, or be passed with amendments or exceptions for members, the next step for me as a concerned Canadian investor will be to express my concerns to the CSA, point to this rule and the concerns I have about the lack of integrity in the American markets, and request the CSA implement a similar rule. I will also request the CSA reach out to the SEC encourage an appeal for this rule to see a second approach. Once more, I ask you pass this rule without amendments or accomodations for your members. Please regulate your industry with integrity, ethics, and resilience against the (predictable) requests from your members not to regulate them.