December 7, 2017
December 7, 2017
Mr. Brent J. Fields
Securities and Exchange Commission 100 F Street, NE
Washington, D.C. 20549
Re: SEC Proposed Rule for Disclosure of Order Handling Information: Release No. 3478309
Dear Mr. Fields,
Thank you for the opportunity to voice my opinions on Disclosure of Order Handling Information. After reading and researching on this topic I have come to the conclusion that this rule should be supported. However, as many previous commenters have suggested, this regulation should not be too heavy handed so as to not hurt the market. While it is important for the SEC to regulate, it must do so to the benefit of the players in the market.
On a whole this is a strong proposal, but I believe that the institutional investors deserve more transparency. If they have more transparency, they will be able to see who they should do business with. They would be able to see which brokers have the best and worst execution quality and they would be able to force the bad brokers out of the market by simply not giving them any money. The best brokers will get much more business and other brokers will be encouraged to improve their trade quality.. To accomplish this, all brokers should have to publish much more information. For example, the effective-to-quoted spread ratios that they generally have would be very valuable to the institutional investors and brokers that truly have their clients best interests at heart will not lose from having this information out in the public. As it stands it is almost impossible to actually gauge the quality of your brokers because the information that is there is hard to put together and incomplete.
Again, I appreciate the opportunity to submit this comment to the committee and hope that all advice is taken into consideration.