Apr. 20, 2022
To whom it may concern, I have concerns about this proposed rule and the creation of SFTs to endlessly pass failed obligations down the line. The mission of the SEC is to protect investors while enabling capital formation. This rule disregards retail investors who are often disproportionately affected by Failure to Delivers and focuses on capital formation for market markers, prime brokerages, and hedge funds who knowingly sell shares they do not own. Susanne Trimbath details in her book Naked Short and Greedy extreme overvoting which is attributed to naked short selling, failure to deliver/receives, and stock loans from the DTCC. This SFT is just another way to obfuscate ownership and does not solve the problem of shares being sold that are either not owned or are not settled. Please remove this rule and focus your efforts on cleaning up corporate over voting and focus on holding market makers accountable for their actions of not delivering shares investors believe they have purchased. Thank you -A concerned retail investor in Colorado