Alexander Wolf Comment On Regulatory Notice 21-19
My comments are as follows: 1. The T-2 settlement period needs to changed to a T-0 or T-evening (the day of). The fact that retail investors have to wait two days, whereas institutional investors don't, violates a free and fair market. 2. Eliminate the loopholes and gaps in the rules that allow institutional investors to wait until T-35 and beyond to settle FTDs. For an example AMC and GME stock were on the threshold list for multiple months of 2020, not just the 13 days that list was intended to inforce. 3. Eliminate payment for order flow. 4.