December 8, 2017
December 8, 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
I appreciate the opportunity to comment on the Securities and Exchange Commissions proposed amendments to rules 600 and 606 of Regulation National Markets (Regulation NMS). As a student in Robert Battalios Trading and Markets class at the University of Notre Dame, I have gained a deeper insight in the market and how exchanges influence it. After considering the SECs proposed changes, I agree with the move towards more transparency regarding broker dealers disclosure to their customer. Markets need to be more transparent in order to create a more efficient market and provide the public with increased market confidence.
The SEC proposes to require broker dealers to provide additional disclosures about the routing of their orders. Rule 606 states that brokers were require to provide quarterly reports on their routing on non-directed orders, institutional investors orders were excluded from this rule. Institutional investors want more and better information about their orders to determine if they are executing at the best prices. Currently the information provided by broker dealers are not enough for institutional investors to evaluate the profitability of their orders. Besides the proposed rules, I would require brokers to disclose the spreads at which they are executing trades. These disclosures are necessary for investors to evaluate their orders and also to keep brokers liable to their clients.
For these reasons I support the SECs proposal to amend rules 600 and 606, though I believe additional requirements should be added. These rules will increase transparency in the market and increase investor confidence in the market.
Mendoza College of Business, University of Notre Dame
Class of 2018