Apr. 20, 2022
As an American and a retail investor the recent suggested rules trying to let banks and hedge funds off the hook for bad bets is not only bad for retail investors but bad for our country. The market already lacks transparency and accountability for large institutions, why are you further obfuscating their actions at the cost of retail? This rule would increase avoidance of price discovery through onward lending. It removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is a very risky business practice. It's all upside for market makers which excessively naked short securities, and all downside for those on the wrong side of their shorting. How does this rule contribute to what you like to claim to be a "fair" market? FTDs are already "reset" through a variety of methods such as using derivatives not allowing them to reach their 30 day mark where the security needs to be "delivered." This is very frustrating to see rules like this being proposed that only favor reckless institutions. Hopefully you'll consider the words of retail investors more with your decision making on regulations, as we've been educating ourselves a lot more over the past couple years. This is my first communication with the SEC with the full knowledge that I have no expectation of fair play or of rules that will be enforced or that my comment will be read or that any change that is good for retail will ever happen. You have lost the public's faith in the market ever being fair and these rules just exacerbate that by flagrantly giving outs to allow dangerous and fraudulent trading to be validated by the SEC. Sincerely, Daniel J Cawley Enterprise Systems Engineer Wycliffe Bible Translators USA wycliffe.org C: 859.569.8661