Subject: File No. S7-14-16
From: Kaitlin R Klawunder
Affiliation: University of Notre Dame

December 8, 2017

December 8, 2017

Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Re: SEC Proposed Rule for Disclosure of Order Handling Information: Release No. 34-78-309 File No. S7-14-16

To Whom It May Concern:

I appreciate the opportunity to provide comments on the Securities and Exchange Commissions proposed amendments for Disclosure of Order Handling Information: Release No. 34-78-309 File No. S7-14-16. Under Rule 606 of Regulation NMS, broker-dealers are required to publish statistical information on their routing practices for non-directed orders. The Commission is proposing to require broker-dealers to make publicly available aggregated information with respect to the handling of customers institutional orders for each calendar quarter.

Under the SEC rules, there is contention on whether or not Rule 606 of Regulation NMS quarterly reports continue to provide useful information for customers placing retail orders in assessing the quality of order execution and the routing practices of their broker-dealers.

I believe the reports could be improved to provide useful information to retail customers. The SEC should require brokers to notify each respective client their effective spread each month, instead of every quarter. This will make the market place more transparent, allowing for an easier environment for naturals to solve their problems. Additionally, the lower the effective spread, the greater the execution quality. Finally, with this change in place, differences across brokers will most likely disappear.


Kaitlin Klawunder
University of Notre Dame Class of 2018