Jul. 22, 2026
Subject: Public Comment on Proposed Rescission of Rule 611 (File No. S7-2026-20) Dear Ms. Countryman, I am writing as an individual investor to express my strong opposition to the Commission’s proposal to repeal Rule 611, the Order Protection Rule (File No. S7-2026-20). If adopted, this proposal will create a two-tiered market structure that works to the distinct disadvantage of retail investors while giving institutional market participants and wholesalers an unfair upper hand. Institutional investors possess direct market access, sophisticated routing technology, and dedicated dark pools. They have the resources required to seek out and demand the absolute best displayed prices across all venues. Retail investors, on the other hand, rely on off-exchange market makers and default routing arrangements. Without the structural safety net of Rule 611, individual investors lose the sole regulatory guarantee preventing their orders from being executed at worse prices than what is publicly available elsewhere. In effect, institutional players will continue to capture optimal execution, while retail orders will be vulnerable to systemic trade-throughs. The Commission’s own release acknowledges this reality, noting that without Rule 611, wholesalers "may begin to trade through displayed round-lot quotes," resulting in "worse prices" for everyday investors and transferring value directly from retail accounts into the higher profits of major firms. It is deeply concerning that a rule costing trading venues a modest ~$31,000 annually to maintain could be repealed at the expense of hundreds of millions of dollars in retail wealth transferred to Wall Street institutions. I urge the Commission to withdraw this proposal. If the SEC moves forward, it must not abandon retail investors without alternative protections. At minimum, the Commission should: Adopt a strict, enforceable Best Execution rule: Establish a binding, objective standard tailored to protect retail investors from institutional trade-throughs—providing real teeth rather than vague, non-binding guidance. Preserve trade-through protections: Replace Rule 611 with a targeted framework that ensures retail orders are never bypassed when a superior price is available in the public market. Thank you for considering the perspective of individual investors. Sincerely, Joshua Clifton