April 19, 2022
Dear SEC Representative,
I am writing this comment to remind you to keep retail investors' best interest in mind. It appears that this specific rule would result in less transparency via SFTs (Securities Financial Transactions) which could effectively enable Failure-To-Delivers (FTDs) to be repackaged, leading to increased systemic risk to the financial system. Instead of enabling and rewarding the failures of brokerages and banks, by allowing them to not have to close out FTDs and never deliver the shares that retail investors buy, I believe it is in the best interest of the market to force buy-ins to let free market dynamics promote healthy price discovery, rather than bailing out those who actively try to abuse the markets for their advantage. If this rule is passed, I believe it will give the message to brokerages to continue to fail-to-deliver and embolden short sellers to continue to abusively short stocks, thereby threatening not only the investors of the company that is being targeted, but also all the employees and any beneficial impact the company may provide to society, such as technology and medicines.
It seems that the complexity of rules that govern our fair market have been mainly created by Wall Street (big banks and hedge funds) who use this complexity (utilizing vehicles such as SFTs) to their advantage. This rule appears to be another example of leveraging complexity to take advantage of investors via less transparency.
I urge the SEC to veto this rule in the name of a free, fair, and transparent market in an effort to protect shareholders and market participants, as well as all those with retirement accounts and hold stock in companies that have been targeted by abusive short selling and FTDs.
Thank you for your time.