Apr. 20, 2022
To whom it may concern. As a retail investor and owner of my securities through a transfer agent(not a beneficial owner), I am highly disturbed by the content of this new proposed rule that would effectively allow for FTD’s (Fail to Delivers) to continue and worsen, which can be abused by market makers and used in conjunction with illegal short selling and abusive dark pool routing to control and suppress the price on security trading. This does not in any way benefit investors and in fact could be extremely harmful, which is anathema to the entire purpose of the SEC’s very existence. Put an end to FTD’s, Allow for instant settlement. The ability for near-instant-settled trades is available, just needs the SEC to protect the markets. Please do not allow SFT’s (Security Financial Transactions) proposed in this rule. SFT’s 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 (this is asinine, trades should be instant-settlement). I can see how it MIGHT provide short term stability and liquidity, but it also allows for abusive practices where market makers are never accountable for their failings. This is not acceptable and creates an opportunity to harm retail investors and it violates our rights for a free and fair market. The manipulation needs to come to an end. Please, Look out for the well-being of retail investors and put and end to FTD’s completely. 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 for a bad policy that does not promote integrity or transparency. The mission of the SEC is to look out for the well-being of investors such as myself, so I would propose that your direct attention to doing so. This would best be accomplished by banning payment for order flow 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 market makers such as citadel which has been used to undermine the true value of securities traded by retail investors and to suppress price discovery. Thanks, Donald Githens, EIT Project Assisstant City of San Diego Engineering & Capital Projects – Program and Project Development Division CIP Analysis and Strategic Forecasting