Subject: File No. s7-32-10
From: Brian higgins
Affiliation: Contracts

July 24, 2023

Time to promote post-trade regulatory
fixes in US:
1) Fine$ + margin call$ for FTDs NO
waivers at NSC's whiml
2) Mandatory Buy-In
3) If buy-in fails, raise offer$ until it
closes.
4) Suspend close accounts of brokers
who FTD 3x/month: SecExch Act
1934, 17A.a.5.(C)

Please mandate buy ins for FTDs. Please eliminate the ability to FTD. Please enact T+0.

We need more transparent markets, which is in large part why I support this rule. This alone isnt enough, but it is a giant step in the right direction, and support the SEC enacting and following through on this proposed rule. Market participants, or rather Hedge Funds, shouldnt be allowed to dilute the number of shares available by borrowing shares they cant locate multiple times over.

We need mandatory buy ins and real fines that equal a greater amount than the profits received from such activity. Fines that are half a percent of profits gained are not a deterrent from such activity. And repeat offenders need to have their accounts closed, licenses suspended, and even receive jail time for manipulation of financial markets that could be construed as theft of the grandest scale.

We need more margin calls for those who cant support their account. And greater transparency is the beginning to that step. Please continue to make the markets more transparent until there is accountability for all market participants to trade on even and fair grounds. PFOF gives unfair advantages but it pales in comparison to FTDs. Because even if PFOF didnt present any conflicts of interest, which is does, FTDs allow the allocation of funds without ever delivering a product. That sounds like theft. Taking money without giving a product is theft. To profit off someone without giving them anything is theft. And Failure to Delivers embodies all of these descriptions. If you take someones money without delivering the agreed upon security, ITS THEFT.