Apr. 20, 2022
To whom it may concern, As a retail investor, I have to voice my objection to proposed rule NCSS-2022-003. This rule would hurt price discovery and prevent a free and fair market. Failure to deliver’s (FTD) cannot continue to be used and this rule would allow other SFT’s to be used to kick the cannon these obligations. The incentive to continue to FTD is increased. In this case, FTD’s look like they are settled but someone else gets robbed. This would allow institutional investors, hedge funds, and large banks to continue hiding short interest and fail to deliver what they are obligated to deliver. The stability this rule would help create is a bandaid on a symptom in which the rich can abuse the system for their own benefit while retail continues to look in from the outside. The abuse needs to stop. The benefit to large institutions with money to invest needs to stop. This system needs to be free for all. It clearly is already not, but to allow this rule would continue to move the pendulum away from protecting retail investors and only benefits the powerful. This rule or variations has been proposed in the past and rejected. This new variant needs to be rejected as well. This rule only continues to create a system where price discovery is absent and retail has no control. For every failure to deliver there is a failure to receive. This is not something retail can control. Please don’t let this rule become a part of a system already working against retail investors. Sincerely, Matt