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. All trades in dark pools must be publicly reported. The fact that institutional investors can make multiple small trades that go unreported violates a free and fair market. 5. Both short and long positions must be publicly reported in a timely fashion. 6. Increase fines and jail time for those who violate these rules. If institutional investors make 100s of millions of dollars from illegal practices, then have to pay a 10,000 dollar fine without jail time, they will accept this as the cost of doing business and continue the illegal practice.
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. All trades in dark pools must be publicly reported. The fact that institutional investors can make multiple small trades that go unreported violates a free and fair market. 5. Both short and long positions must be publicly reported in a timely fashion. 6. Increase fines and jail time for those who violate these rules. If institutional investors make 100s of millions of dollars from illegal practices, then have to pay a 10,000 dollar fine without jail time, they will accept this as the cost of doing business and continue the illegal practice.