Subject: S7-29-22: WebForm Comments from Greg Linder
From: Greg Linder
Affiliation: Founder and CEO, SolarSCADA

Jan. 12, 2023



January 12, 2023

 So. This is a good rule, so far as helping provide real time information in the emerging real-time market.

That being said, I'd like to see some real traction on closing the loopholes outlined by Dr. Trimbath, including order internalization, dark pools, and exploiting T+3 settlement and existing FTD policies.

It makes sense to me, in market where the SEC is honestly requiring sub-msec data reporting, to force all shares to be delivered in real time as well. This would remove the capabilities (and the need) for \"wholesalers\", since every entity, including nearly all retail investors, have access to low latency interfaces capable of interfacing directly with an exchange.

FTD's, T+3 order settlement, and share rehypothecation through locates and options straddles are market strategies only available to large players- The data reporting requirements and speed should definitely be increased, as per this rule, but no proposed rule changes I've seen recently does anythign to prevent the blatant and obvious manipulation caused by FTD's and naked short selling. The SEC knows these issues exist, and has fined many entities for violations of said rules in the past, yet the amazingly huge gaping loophole remain open, and exploiting, causing damage to the US economy and hurting the competitive advantages inherit in the entire market system.

So, getting better data is important, but it's not like it's not already known based on current data feeds what is happening.

Even so, I appreciate that the SEC appears to be listening the groundswell of retail investors who are now paying attention to these systems like never before. Thanks for your time.