Apr. 19, 2022
Hello, From my understanding of this overly and unnecessarily complicated rule, is that it proposes using a vehicle, called an SFT (Securities Financial Transaction). This works as a placeholder for any securities transaction. As I understand it, these SFTs are fungible like a dollar bill. So, if you have $100 worth of SFT that you SHORTED, and want to Fail-to-Deliver (FTD) rather than buy-in at market value, you can resolve it by utilizing another SFT worth the same amount set for the same delivery date. The cost one would pay for this "feature" would be based on the difference in closing price from one day to the next. This cost would be much cheaper than a market buy-in further increasing the level of inequity and fairness in the market for retail investors. Seems like a cheap way to can-kick a FTD problem, rather than buy-in at current market value. I.e. seems crafted to protect the practice of ABUSIVE and NAKED SHORT-SELLING, when it doesn't work out for the entities holding short positions. It means exponentially increased share-lending without accountability for Bad Actors making poor choices and putting everyone else at risk. Thank you for your time. C. Kenny