Subject: Feedback on SR-NSCC-2022-801
From: Brandon Wood
Affiliation:

Apr. 20, 2022

 


To whom it May Concern:

As a retail investor I am outraged 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. This proposed rule does not in any way benefit investors and in fact would be extremely harmful, which is counter 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. 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 creates an opportunity to harm retail investors and it violates our rights for a free and fair market. Quite plainly stated, it is criminal. To have a truly “free and fair” market, the manipulation needs to come to an end. Do not impose this rule.

Regards,

Brandon Wood
Aerotek
Microsoft OCI Buyer/Expediter