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Archer Comment On Regulatory Notice 21-19


I would like to propose a fixed T+0 or T+1 settlement date for all shares. FTD's (Failure to deliver) are rampant in the current market structure and allows for adverse effects on price discovery. Enforce a T+0 or T+1 settlement for FTD's and this would saveguard price discovery and mop up shorting fraud without risking liquidity issues.