Aug. 26, 2022
August 26, 2022 SECURITIES AND EXCHANGE COMMISSION 17 CFR Parts 240 and 242 Release No. 34-95431 File No. S7-21-22 RIN 3235-0695 Clearing Agency Governance and Conflicts of Interest I'd like the commission to look at historically how clearing agencies registered under the commission have settled trades for securities and how long they have taken to deliver the assets. The use of dark pools seems to be a troublesome indicator of price discovery for retail orders, perhaps a look into that as well. Earlier SEC Chair Mr.Gensler, mentioned when he took office that T+0 clearing would be done, but the fact a lot of investors pay for shares and the items not being delivered makes me think that self regulation has failed in these organizations and they require a better framework, oversight and governance. Not on a weekly and once a day basis, more like on a constant basis. Lastly the governing bodies of such agencies should not have personnel who work for a clearing agency, Hedge fund, Market Maker or any financial institution of such status, where this creates a conflict of interest situation for them, a situation that no one wants. Ensuring this would require people working in the government, regulating finance are well funded and are compensated competitively. Say if someone worked for the SEC or a SRO and then went to join the board of a big hedge fund, they should have a cool off period before they can join such roles, say 3-5 years.