Subject: SR-NCSS-2022-003
From: Ben Espina
Affiliation:

Apr. 20, 2022

 



To whom it may concern: 



As a retail investor I am highly disturbed by the content of this new proposed rule that would effectively allow for FTDs (Failure To Deliver) to continue and worsen. This does not in any way benefit investors and in fact could be extremely harmful. 


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 it provides stability in the moment, but it also allows for abusive practices where market makers are never accountable for their failings. This would dissolve fundamental market foundations and create an inherently unstable and fraudulent system that will inevitably lead to a major economic catastrophe. 


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. 


Thank you in advance for your timely attention to this matter. 


Sincerely, 


Benjamin Espina