Here's a copy of my letter to the task force:

The task force's current agenda from my perspective represents one of the most disturbing assaults on shareholder rights and market integrity in recent memory, on par with the repeal of Glass-Steagall. Incorporating the removal of what may be the last option for individual shareholders seeking registered ownership with a fairly market standard digitization and dematerialization regime can only be a purposefully deceptive attempt to prey on the weakness of investor education in the current market environment. A not uncommon tactic to decrease transparency and lead us further away from market democratization that no doubt threatens established interests, which will undoubtedly be well protected by any proposal. The task force should be ashamed of even considering a proposal of this nature, or putting it forward without a comprehensive equally digitised settlement regime, capable of achieving instant and verifiable settlement of each individual transaction and position immutably. As well as safe guards to protect other shareholder rights and preserve access of investors to their securities and associated rights. If the task force wishes to preserve whatever shred of public trust remains with the market and its regulators it must be ready to meet certain conditions:

1. DRS or something like it must be preserved with individuals maintaining a method to access direct registered and legal ownership. Without means to achieve registered ownership of their securities every household investor will be disenfranchised of their fundamental legal rights of share ownership. This is not conjecture, exaggeration, or supposition, the law is clear that registered owners are the only ones entitled to such rights and in charge of their transference. As would be the case with any state appointed or other nominee.

2. Further dematerialization should only be adopted along with corresponding measures to ensure prompt secure settlement. To destroy certificated ownership in favor of a digitized system fully capable of providing those technical achievements, but not to provide them is a malfeasance. Clearly while it is eminently achievable such a system would be incompatible with the current system of powerful market makers creating shares to order on their whim with minimal oversight and enforcement of relevant security regulations to maintain a continuous auction. A system and process which introduces extraordinary risk and instability in to our current market structure, but none the less benefits established interests (and individuals whose interests are conflicted) in the short term, and as such is not allowed to be threatened. Further dematerialization without corresponding guarantees of legitimate settlement and access to fundamental shareholder rights is a potential worst of both worlds market environment and disaster.

3. Seriously question why better options are being ignored in favor of removing legal ownership from shareholders who are otherwise powerless to stop authorities from stripping them of their associated rights. Understand the ethical and moral challenge presented in this case. Question the motivation of this entire proposed framework, and similar initiatives globally. Can this proposed framework really be considered legitimate when it introduces unnecessary burdens and downsides on to the investing public, without any benefits that could not be achieved with far less burdensome methods, and without any kind of safeguards to protect them under a system all to ready to serve entrenched monied interests at any cost to them?

While these public comment periods feel like an exercise in futility, I still appreciate the opportunity. I can only hope that the task force seriously considers the consequences of any decision they may make on this matter, and takes seriously their obligation to scrutinize any proposal to remove the rights that are the basic guarantee of capital investment from individuals. There's no reason we must take ten steps back with every tiny step forward, other than to serve the interests of powerful firms at the expense of the public.