December 7, 2017
December 6, 2017
Brent J. Fields
Securities and Exchange Commission
100 F Street, NE.
RE: File Number S7-14-16, Disclosure of Order Handling Information
Dear Mr. Fields,
Thank you for the opportunity to provide comments on the Disclosure of Order Handling Information proposed rule. This semester I have had the opportunity to take Robert Battalios class Trading and Markets at the University of Notre Dame, which we discussed the ruling and its implications. After a careful study of the proposal to amend Rules 600 and 606 of Regulation National Market System under the Securities Exchange Act of 1934, I have come to agree with the proposal since it provides more fairness and efficiency to the market. Specifically Rule 606 of Regulation NMS that requires broker dealers, upon request of their customers, to provide specific disclosures related to routing and execution of the customers institutional orders for the prior six months will provide more fairness to the market.
In todays markets due to the changes in market structure brought about by Algorithmic Traders, new venues and new routing practices, order handling information has become more important for institutional traders given the volumes which they trade. However, there is no standardization with regards to the disclosures that broker-dealers must submit to their customers or give upon their request on the order routing information. By providing this information institutional customers will be more fit to assess the impact of their order given the order routing decision that their broker-dealer took. Therefore, by requiring more disclosure of information on the decisions taken by the broker-dealer, the interest of institutional customers will be better served. However encouraging transparency is not enough, there should be standardization of the information produced. Since standardization of the information as Rule 606 calls for will put all institutional investors in an even playing field with respect to the available information.
Therefore, to increase fairness and transparency in the market I support the proposed amendment to Rule 606. Since it will not only foster enhanced information for the institutional customer, but also foster improved quality of broker dealers order handling practices since they will be under more scrutiny.
Maria Fernanda Alfaro
University of Notre Dame
Class of 2018