Subject: SR–NSCC– 2022–801
From: Milton Braz Rubim Neto
Affiliation:

Apr. 20, 2022

 


As a retail investor I am trully perturbed by the content of this new proposed rule that would effectively allow for FTDs (Failure To Deliver) to continue and worsen, which can be abused by market makers and used in conjunction with illegal naked shorting and abusive dark pool trade routing to control and suppress the price on security trading. This does not in any way benefit investors and in fact could be extremely prejudicial, which is opposite to the entire purpose of the SECs very existence.


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. 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.


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. 

Thank you in advance for your timely attention to this matter, and please live up to your obligations and help the investors from predatory behavior by financial institutions.


Sincerely,


Milton Braz Rubim Neto 
Retail Investor