Apr. 19, 2022
Dear SEC, I am opposed to this rule change. It is actively harming my ability to conduct investment in United States Securities market. This rule continues the bifurcation of markets into 1) the market where retail investors are taken advantage of and 2) the market where a few powerful and wealthy investment firms are able to have unfair advantages and essentially cheat anyone in the "other market". That is not a free market. That is a market where having access to more money and capital allows for what would currently be consider cheating aka illegal activity aka slap on the wrist fine for the wealthy. This rule proposes using SFT, as a placeholder for any securities transaction. These SFTs are to be fungible like a dollar bill. So, if you have 100 worth of SFT that you SHORTED, and want to Fail to Deliver 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 could in practice be many more times cheaper than a market buy-in. This is just a cheap way for wealthy and powerful investors that made bad trades to never pay what they owe in a fair market when they have a Fail to Deliver problem. Rather than buy-in at current market value. This rule seems to be crafted to protect the practice of abusive short-selling when that practice doesn't work out for hedge funds that are short. When a few are able to cheat the market in this way faith in US institutions is eroded. Faith in the future of the entire US economy is eroded. I am opposed to this rule change as a retail investor. Regards, Kyle Vonderwerth