Subject: Comment on proposed rule: SR-NSCC-2022-003
From: Will Dickerson
Affiliation:

Apr. 20, 2022

 





To whom it May Concern:
I am a retail investor, and I am highly disgusted by the contents of this proposed rule (SR-NSCC-2022-003) that would effectively allow for FTDs (Failure To Deliver) to continue and worsen. This rule could be abused by market makers and used in conjunction with illegal naked shorting and dark pool trade routing to control and suppress the price on security trading. This does not in any way benefit any investors and in fact could be extremely harmful, which is antitheses to the entire purpose of the SEC's very existence.
Do not allow SFTs (Security Financial Transactions) proposed in this rule, to create new and potentially infinite layers of postponement to be allowed, whereby the very real financial obligations of the FTDs get passed along instead of settled. I can see how it provides stability in the moment, but it also allows for abusive practices where market makers are never accountable for their failings. This is not acceptable and creates an opportunity to harm retail investors and it violates our rights for a free and fair market. The manipulation needs to come to an end.
Please remove this proposed rule and furthermore please do not try to propose something similar again in the future, as at least two iterations of this have been rejected in the past and continue to be rejected by educated investors every time they resurface. What a colossal waste of everyone’s time to continue to have to repeat this song and dance over and over again.
Is it not the mission of the SEC to look out for the well-being of investors such as myself? I would propose that you direct your attention to doing so. This would best be accomplished by banning Payment For Order Flow which is inherently harmful to retail investors and which unfairly benefits Market Makers and brokers who do not have retail investors best interest in mind. Another worthy target for your attention would be to shut down the abusive use of dark pools by market makers such as Citadel which has been used to undermine the true value of securities traded by retail investors and to suppress price discovery.
Thank you for your timely attention to these matters and live up to your self-appointed mission to help keep all investors from predatory behavior by financial institutions.
Sincerely,
Will Dickerson