Apr. 20, 2022
To Whom It May Concern, As a Retail Investor, the subject rule being proposed does not benefit or protect me in any way. FTDs (Failure To Deliver) are already a big problem within the market and implementing this rule would make it considerably worse. I’d like to believe that the SEC is here to protect investors as it is stated in their mission statement, but some of the recent proposals that have been brought forward, leads me to believe that the SEC is failing investors and benefitting the big players on Wall Street. I would very much like to see this proposal DOA (Dead on Arrival) and for the Commission to consider not implementing rules like this ever again. I believe it benefits everyone to be as transparent as possible and for all parties involved to meet their obligations. Thank you for your time. I copied this one, changed some of the words because there's spelling issues. The market already lacks transparency and accountability for large institutions, so im disappointed this rule is being proposed. I've read every single page of legal speak in the file and it is very clear what this rule proposes. This rule would increase avoidance of true market price discovery through onward lending. It also removes the infinite risk of naked shorting entirely, and in so doing the deterrent of engaging in what is supposed to be 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 a "fair" market by any means...? I don't see it. FTDs are already "reset" through a variety of methods such as using deriviatives 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. and one more I am writing as a retail investor to express concern over this rule and its implications. As I understand it, this allows an essential like-exchange agnostic to the success of a company wherein $100 (or $100MM) of an abusively shorted stock can be exchanged for $100 (or $100MM) of any other stock, thereby eliminating the risk of short selling. When any person or entity short sells a stock, they knowingly take on that risk and should have no other way out of that gamble other than to purchase that stock back to satisfy the debt that comes with a short sale. Imagine, if you will, you bet against someone in poker with a bluff. The person across from you goes all in, and they are holding a flush. You bluffed with a two-pair, but thanks to a rule like this, you can swap your two-pair for a four-of-a-kind. That is unethical and breaks the rules of poker. You allow this bluff to turn around into a win at the expense of the player with the better hand. If you allow "rules for me, not for thee" as what's suggested here, you blatantly hand all abilities to legally manipulate the market (at will) to those who have repeatedly abused and continue to abuse any and all advantages they are given over retail and institutional investors alike. Please keep in mind, you are also dealing with entities who will gamble away the pensions and retirement accounts of hard-working Americans. If they are callously betting with mind-boggling levels of leverage, they must be held accountable when their bluff is called and they must stop their abuse of rules that have, for far too long, given an unfair advantage. Sincerely, Michael Frent