Apr. 20, 2022
To whom this might concern: As international a retail investor I am highly disturbed by the content of this new proposed rule that would effectively allow for Failure To Delivers (FTDs) to continue and worsen, which can be abused by market makers and used in conjunction with naked shorting and dark pool trade routing to control and suppress the price of equities. This does not, in any way, benefit investors and is likely to be extremely harmful to the vast majority of investors. Please do not allow Security Financial Transactions to allow new methods of negligence, whereby the financial obligations of the FTDs get passed along instead of settled. This proposed rule is shorted sighted in its attempt to create stability and allows for abusive practices where market makers are not held accountable for their failings. In order for the equities markets to be fair, market makers must be held accountable for their financial obligations, regardless of the short or long term consequences they face. Stabilising the financial system where market maker privileges already result in continuous FTD (which is by definition not fulfilling on a promise to deliver shares in exchange for currency - vulgo: stealing) will have negative medium-run consequences of market efficiency. It will also make short and distort tactics highly profitable as the only check and balance to this behaviour, which is the unlimited risk of being on the wrong side of the bet, will be negated. I as a international investor to the US capital markets request that this proposed rule be denied and that similar rules are not proposed in the future. The repeated attempts for such a measure to be passed after multiple rejections points to the potential desire for malpractice by market makers. Thank you for your timely attention to this matter, and please honor your obligations to protect investors from predatory behavior by financial institutions. Best regards, Alexander Kuchta Germany Von meinem iPhone gesendet