June 21, 2023
The proposed SEC rules, while noble in intent, risk further clouding the financial markets with undue complexity. We should instead strive for simplicity and directness by significantly limiting Failures to Deliver, a clear source of market disruption. Above all, restoring and maintaining trust with market participants, regulators, and the public should be our guiding principle.
or put another way
(Gollum voice) \"SEC ruleses, tricksy they are, precious, all twisted and tangled like nasty hobbitses hair. (Coughs) But we knows a better way, yes, we does, precious. We stops the nasty Fails to Deliver, makes the markets nice and smooth, like a shiny fish. (Smeagol voice) Yes, yes, trust is what we needs, precious, like the warm sun on our skin, not the cold, dark cave of confusions. We needs trust, precious, and clear rules, yes, clear and bright as the moonlight on the water\"
or put another way
Esteemed stewards of our markets fair,
Unto you, my thoughts I wish to bare.
I write in deep concern, forsooth, to contest,
Your proposed rules that aim to arrest
Misdeeds in swaps of securities based,
And undue influence, with haste displaced.
Yet I find them riddled with complexities vast,
And fear they serve to obfuscate our path.
Whilst Rule Fifteen FH- Four C indeed,
Guards the Compliance Chief from overreach,
The scope and language doth exceed,
A simple rule's more eloquent speech.
Rule Ten B-One, transparency seeks,
In the security-based swaps marketplace,
But in its labyrinthine technique,
Does it not the true issues misplace?
In its stead, I propose, with modesty due,
A rule simple, straightforward, and true.
Limit FTDs, those disruptions dire,
By ninety-nine percent, set the bar higher.
But a lack of trust still shadows my plea,
Gary Gensler and SEC, do you hear me?
For the memory lingers of slights endured,
The pie in my face, my name obscured.
Transparency, fairness, trust restored,
Is it not these we should strive toward?
To end manipulation and fraud so rife,
Would not such rules better serve public life?
So hear my plea, ye guardians of trade,
For the foundation of trust must be relayed.
In the spirit of the Bard, my message is clear,
Simplicity and trust, not obfuscation, we hold dear.