Apr. 20, 2022
To whom it may concern, After reviewing the proposed ruling SRC NSCC 2022-801 I must voice my serious concerns opposing this ruling. A free and fair market is predicated on the concept of transparency and a buyer matched with every seller. Failure to deliver purchased shares should rarely happen and allowing this practice to continue without fixing the underlying problem is an affront to the principle of a free market. It is clear FTDs cause significant harm to companies by disallowing natural price discovery, dilution of the free float of shares by artificially increasing the total amount in circulation and can have deleterious effects on corporate governance as voting preferences are similarly devalued and diluted. This is the third time a similar ruling has been proposed and it is clear that the current markets have serious problems with FTDs. By allowing the practice of FTDs to continue unabated, further damage to the market including loss of faith and subsequent disinvestment of funds by retail traders. I strongly urge governing bodies to understand that retail investors are more informed then they have ever been. They understand the problems associated with failing to deliver stock as a function and understand that it should not be considered part of normal market functions. It is time to fix the root of the problem as opposed to attempting to temporarily patch the symptoms of the deeper underlying issue. Dan Phillips