Subject: SR-NSCC-2022-003
From: Evan Devillier
Affiliation:

Apr. 20, 2022

 


Greetings, 


The content of this new proposed rule that would allow for "Failure to Deliver" (FTDs) to continue and become worse is HIGHLY disturbing, and must not come to pass. This can and WILL be abused by market makers to continue to control and suppress price discovery on securities trading, who operate completely in the dark with little oversight and effectively ZERO transparency, so this proposed rule is a huge slap in the face to our free market economy. The role of the modern market maker is less about creating liquidity, and more about making money on both sides of every trade by obfuscating what's really happening, and this causes FTDs. Hold the market makers accountable when they find a "buy" or "sell" for investors, as that's their responsibility. Otherwise, what the hell are we even buying? 


It is your job to protect retail investors, and this proposed rule DOES NOT IN ANY WAY benefit investors, and can be extremely harmful to faith in the market, as it goes against the theory of a free market economy. What would you rather: high liquidity in a fraudulent market, or slightly less liquidity in a legitimate market? If the latter sounds better to you, AS IT SHOULD, get rid of this garbage rule. Do not let special interests convince you that this is a good idea. At the same time, we need more transparency as to how they operate, but that's a topic for another day. 


Do not allow Security Financial Transactions (SFTs) proposed in this rule to create new and potentially endless layers of "kicking the can down the road". Whatever short-term issue this short-sighted rule is being marketed/proposed to fix, it will blow up in all of our faces even harder if you don't let it run its course naturally, and you will be to blame for the added pain to every retail investor. In a legitimate market, FTDs need to be accounted for, and shares need to be delivered when a market maker says they found a share. We need to hold accountable entities that lie about finding and buying securities in investor's name. This is fake "liquidity" built on fraud, and allowing this rule will help to legitimize their shady practices to the detriment of retail investors. 


This is completely unacceptable - reject this rule and don't accept similar proposals. Every time a rule like this comes up, smart investors who are actually paying attention shoot it down with comments, and special interests are betting that eventually we will stop caring, but we won't. So quit wasting MY and YOUR time by bringing this crap up over and over. 


Regards, 
-Evan Devillier