Apr. 20, 2022
To whom it may concern, As an American citizen and retail participant in the markets, I believe this proposed rule introduces, or perhaps perpetuates, a dangerous and risky practice for the American economy. Any rule changes that enable a failure-to-deliver in our securities markets serves to promote a failure-of-service to participants in the market. Those who come to the American securities markets seeking price discovery and first-world, first-class competitive market practices may not find this to be favorable or fair. If the self-governing entities that dictate market structure and market practice in this country require a vehicle to produce cash collateral for their own inability to deliver on their accepted fiduciary responsibility as it pertains to clearing market transactions, then I believe that is a market failure in of itself. In my opinion, the solution is not to enable the behavior but instead to pin accountability where it is due. The founding principles of a market system require that there are competitive solution to failures - not regulatory ones that make those failures just another part of the resulting no-longer-competitive system. As a country, our willingness to accept failures of our system as just another outcome to take into account rather than a problem that needs inherent, foundational fixing has either become or resulted in relevant issues to the average American - whether it be inflation, coronavirus, or injustice. I could elaborate further on this connection, but I want to keep this brief as I hope you have lots of these letters to read. Thank you for your time, Ian Lawson