Apr. 20, 2022
To whom it may concern:
As a retail investor and proponent of fair and transparent markets, I am extremely concerned and disturbed by the content of this new proposed rule. This rule would effectively allow for FTDs (Failure To Deliver) to continue unanswered and amplify the systematic risk it already presents to not only US markets, but global economies in tandem. This rule can be abused by market makers and other non-retail investor market participants and used in conjunction with illegal naked short selling and abusive off market exchange (dark pool) trade routing to control and suppress the price on securities trading. The latter being reason for concern in itself as it can lead to securities kiting fraud and Ponzi scheme-esque internalization of trades while unbeknownst to most retail participants. This does not in any way benefit retail and institutional investors and in fact could be extremely harmful, which is anathema to the entire purpose of the SECs very existence. It is the SEC's responsibility to protect the interest of market participants without substantial capital market influence.
Please do not allow SFTs (Security Financial Transactions) proposed in this rule, to create new and potentially endless layers of debt avoidance ("Can Kicking") to be allowed, whereby the very real financial obligations of the FTDs get passed along instead of settled or neglected entirely. I can see how it provides stability in the moment, but it also allows for abusive practices where market makers are never accountable for their failings. This is not acceptable and harms retail investors. It violates our rights for a free and fair market and creates destabilizing risk to our capital markets as it rapes the unsuspecting and creates concern that all market confidence could be lost. This criminal manipulation must come to an end.
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 defend the general public from this attack on market fairness.
The mission of the SEC is to look out for the well-being of investors such as myself, so I would propose that you direct your attention to doing so. This would best be accomplished by banning Payment For Order Flow (already illegal in most global financial markets) which is inherently harmful to retail investors and which unfairly benefits Market Makers and brokers who do not have investors' best interest in mind. Another worthy target for your attention would be to shut down the abusive use of dark pools by privately owned market makers such as, but not limited to, Citadel Securities LLC which has been used to undermine the true value of securities traded by retail investors and to suppress price discovery. The naked short selling tactics used by these market participants is a clear bastardization of the allowance to naked short sell, which would otherwise be illegal, for market liquidity purposes allowed via Reg Sho. Show that the SEC is truly acting in the interest of the general public and stop this now.
Thank you in advance for your timely attention to this matter, and please live up to your obligations and protect the investors from predatory behavior by financial institutions. The American people and investors across the globe are depending on you to do your job and protect them from this egregious proposition. The people are watching. They will not forget and they will not forgive. Never again should the American people bail out wall street only to have them double down and destabilize the system we all depend on. Enough is enough. God bless the United States of America and may he and our courts judge you fairly based on your actions.
Sincerely,
Dillon Michael Wells