Subject: SR-NSCC-2022-003
From: Connor Geraghty
Affiliation:

Apr. 20, 2022

 


To whomever this concerns, 


I am a retail investor and genuinely and deeply concerned that the proposed rule, which seems similar to other rules already proposed and subsequently withdrawn, would allow for FTD (Failure To Deliver) to carry on indefinitely. Effectively allowing short positions to be carried on to infinity with no market buy-in. This can and will be used in conjunction with illegal naked shorting and dark pool trade abuse to control and suppress price on trading. 


This does not, in any way, benefit investors and will likely be extremely harmful to these same investors. That is counter to the SECs very purpose and existence. 


Please do not allow SFTs (Security Financial Transactions) proposed in this rule to create potentially endless layers of FTD can kicking. This invalidates the real financial obligations of the FTDs to be passed along instead of settling. It can provide stability in the moment, but what it does in the long term is create a very strong opportunity for abuse by market makers that have already proven to not willingly play by the rules. Putting any fines levied against them as a cost of business instead of a lesson learned or real warning with weight. This is not acceptable to create a new system that actively harms retail investors and violates the principles of a free and fair market. This manipulation has to end. 


Please remove this proposed rule and do not reintroduce it in the future with slightly changed language. Past iterations of this rule have been rejected and withdrawn for good reason. This proposition is a massive waste of time and resources of everyone involved on the retail side of investment. 


The mission of the SEC is to look out for the well-being of investors like myself, so please direct your attention to doing just that. This can be facilitated by banning Payment For Order Flow, which is inherently harmful to retail investors and unfairly benefits market makers that trade in advance of these orders being executed. Ignoring their obligation for best execution over making money for their firms. An even more substantial use of attention and resources would be to end the abusive practice of Dark Pools by market makers, e.g) Citadel, which is consistently used to suppress price discovery. 


Thank you for your time and attention to this matter. Please live up to your obligations and help protect retail investors from predatory behavior by financial institutions. 


Sincerely, 
Connor Geraghty