Jul. 29, 2026
Dear Ms. Countryman, I am writing to you today as a concerned individual investor to voice my unequivocal opposition to the proposed rescission of Rule 611, the Order Protection Rule (File No. S7-2026-20). This rule, for two decades, has served as a foundational safeguard for everyday investors like myself, ensuring that our orders are executed at prices no worse than the best publicly displayed quotes across the market. It represents a critical, order-by-order defense against adverse pricing, and its removal, without any substantive replacement, would expose millions of retail investors to significant financial detriment. The potential ramifications of this proposal are not speculative; they are explicitly acknowledged by the Commission itself. The very release detailing this proposal concedes that its repeal could lead to wholesalers "trading through displayed round-lot quotes," which would inevitably result in "worse prices" for individual investors. It further admits that this would "transfer value from the retail investors to the wholesalers, who would earn higher profits." This admission is deeply troubling. To deliberately enact a policy that is anticipated to reduce the value of individual investors' trades for the direct benefit of large Wall Street firms is fundamentally contrary to the Commission's mission to protect investors and maintain fair, orderly, and efficient markets. We, as individual investors, should not be compelled to subsidize the profits of market intermediaries through less favorable pricing on our transactions. Furthermore, the economic rationale presented for this rescission appears profoundly skewed. The Commission estimates the compliance cost for each trading center to be approximately $31,000. This nominal figure pales in comparison to the projected harm to investors, which is estimated to reach hundreds of millions of dollars annually. This is not a balanced trade-off; it is a clear prioritization of a minimal compliance burden for market participants over the substantial financial well-being of the investing public. This imbalance is unacceptable and undermines confidence in the fairness of our market structure. Therefore, I strongly urge the Commission to reconsider and withdraw this proposal in its entirety. The Order Protection Rule is a vital component of investor trust and market integrity, and its removal would be a severe step backward. Should the Commission, despite these compelling concerns, proceed with removing Rule 611, it is absolutely imperative that robust, enforceable investor protections are established *before* such a change takes effect. We cannot be left unprotected. At a minimum, this would necessitate the immediate adoption of a clear, objective, and rigorously enforceable best execution standard specifically tailored for individual investors. This standard must represent a genuine, substantive improvement over past efforts like the withdrawn Regulation Best Execution, not merely another set of ambiguous guidelines or unenforceable principles. Alternatively, at the very least, a narrowly tailored mechanism must be implemented to preserve the core trade-through protection that Rule 611 currently provides, rather than eliminating it completely and leaving individual investors exposed to predatory pricing practices. Thank you for your time and for considering the profound implications of this proposal on the millions of individual investors who rely on a fair and transparent market. Sincerely, Concerned Investor