April 20, 2022
There already exist a multitude of problems in the current formulation of the NYSE that hinder retail to the benefit of the bigger players. PFOF, dark pools, naked shorting, and FTDs all hurt the individual investors who are trying to leverage the success of a free market system.
This new rule simply must not pass. The problems of the Failure to Deliver (ie, I promised Id deliver this product, but I end up failing, and the penalty for such behavior is minimal) should be addressed first the intent of this new rule seems to allow FTDs indefinitely, and not require their settlements. This would create an environment ripe for abuse by the major market players in taking advantage of the investments of individual participants.
We should, instead, be looking to fix root-causes and not provide \"band-aid\" liquidity fixes. Institutions who are over-leveraged in specific positions must be forced to face the consequences of those poorly-chosen positions. The problems facing the market hurt natural price discovery -- these must be addressed, not hidden away or \"baked\" into the system.
Please do not pass this rule. I am concerned the system continues to stack itself in favor of certain individuals over others, and a free market simply does not do this.