Sep. 14, 2023
To Whom It May Concern: I write today to comment on the proposed filing File No. SR-FINRA-2023-11, in which the Financial Industry Regulatory Authority (FINRA) seeks to be granted yet another extension from margin requirements that were implemented 7 years ago in 2016 and are set to go into effect on October 25, 2023. I appreciate this opportunity to publicly state my concerns. In 2016, this underlying margin requirement rule, SR-FINRA-2015-036 was approved and implemented by the Securities and Exchange Commission, yet 7 years later, in 2023, not only has this critical risk-management protection not become a widespread daily feature to safeguard our financial system from another crash such as the one we experienced in 2008, but, still, there are attempts to further postpone and prolong the application of this very important regulatory measure as seen in this recent filing, SR-FINRA-2023-11. The time for delaying is over and these rules created almost a decade ago need to be in place as of yesterday. Since the issue seems to be with increased margin requirements and capital obligations, consider the fact that a normal citizen can't just delay his mortgage payments year after year when times are tough. It's past time for the system to mature to the point that jobs are actually completed and implementations are followed through efficiently and swiftly. Consumer and Investor Protection laws need to be enforced with the highest priority. This is mandatory for the stability of our financial markets. There is absolutely no good reason or excuse to delay the full implementation of SR-FINRA-2015-036 any longer. For the protection of the public, please reject SR-FINRA-2023-11 and enforce the completion of the margin requirements that have evaded existence for 7 years, on the date that is currently law, October 25, 2023. Enough time has passed for study and consideration of the law's effect on financial systems. Consider studying the real-time effects now, and we can progress as a society. Very Concerned Why There Is This Much Delay In Rules Designed To Protect The Public, Juan B., Business Owner