Apr. 20, 2022
To whom it May Concern: I am very concerned by the content of this new proposed rule that would give short sellers another avenue to avoid settling their obligations and preventing an FTD from being recorded. This doesn't serve the overall market in any beneficial way and seems to be a rule directly aimed at helping short sellers continue opening additional short positions when they shouldn't be able to. Please do not allow SFTs (Security Financial Transactions) proposed in this rule, to create new and potentially endless layers of can-kicking to be allowed, whereby the very real financial obligations of the FTDs get passed along instead of settled. I can see how this rule could provide more stability in the short term, preventing excess volatility. However, in practice, allowing FTD obligations to be deferred enables abusive practices and sacrifices authentic price discovery, seemingly with the only reason being to satisfy the reckless short selling habits of some firms. Behavior like what I've described has been deemed acceptable for too long and has harmed many investors' faith in the market. These practices need to end if our country wants to claim we run a free and fair market. This rule stands in direct opposition to this goal. Please remove this proposed rule and furthermore please do not try to propose something similar again in the future, as 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 time, mine and yours, to continue to have to repeat this song and dance over and over again. Thank you in advance for your timely attention to this matter, and please live up to your obligations and help the investors from predatory behavior by financial institutions. Sincerely, Chauncey Dewey