Apr. 20, 2022
To whom it May Concern: I am a retail investor and I am extremely distasteful by the contents of this new proposed rule that would effectively allow for FTDs (Failure To Deliver) to continue and worsen without remorse. Therefore if this rule goes through, FTDs will be abused by market makers and used in conjunction with illegal naked shorting, abusive etf shorting to hide short interest, and abusive dark pool trade routing to continue to control and suppress the price on security trading. Even Stacey Cunningham, the president of the NYSE, specifically states in an interview that “stocks that have a high level of retail participation, the vast majority of order flow can trade off of exchanges (dark pools), which is problematic.” If this rule comes through this will only worsen the disconnected supply and demand in the free markets that America has built under the freedoms of the Constitutions. This rule does not in any way benefit investors and in fact could be extremely harmful, which is the premise of the SECs very existence. Please do not allow SFTs (Security Financial Transactions) proposed in this rule, to generate even more Failure to Delivers and allow for those participants to not deliver these shares. By passing this rule, it will ruin the faith we have in the financial markets and showcase the favorness of the institutional investors, this will show that the free market is not just and fair. 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. The manipulation needs to come to an end. 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. This is a complete utter waste of time, as a similar proposal has been rejected and this proposal does not fit the agenda of the American people, but rather the market makers, hedge funds, and other institutional entities. The mission of the SEC is to look out for the well-being of investors such as myself, so I would propose that you direct your 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. Payment For Order Flow benefits way more for the wholesalers because they can see the stop losses, trades, and much more of the retail investors. Through this, these wholesalers can take advantage and bust these retail investors positions such as the event that unfolded on March 10th 2021 when $GME went from roughly $350 to $170 in a matter of 40 minutes. Still to this day this event still has not been addressed. Another worthy target for your attention would be to shut down the abusive use of dark pools by market makers such as Citadel and Virtu which has been used to undermine the true value of securities traded by retail investors and to suppress price discovery. Thank you for your time in taking to read this comment and I hope this rule can be rejected, as it gives predatory short sellers the benefit of never meeting their FTDs. All the best Bob Nod