Subject: S7-18-23: Webform Comments from William Carlson
From: William Carlson
Affiliation: Household Investor and Software Developer

Dec. 22, 2023

Hello,

As a seasoned investor with over ten years of experience in managing
my own investments, I've observed a concerning trend in the U.S.
financial markets that I believe needs urgent attention. My main
concern revolves around the practice of Payment for Order Flow (PFOF),
which, in my opinion, is a detrimental approach affecting both the
efficiency and fairness of the market.

The core issue with PFOF lies in its operational model. This system
prioritizes bids based on financial compensation rather than focusing
on the best execution for trades. Such a mechanism dilutes the
competitive nature of the market, shifting the focus away from
achieving optimal trading conditions.

Furthermore, PFOF introduces significant conflicts of interest. When
exchanges provide rebates for specific order types, it essentially
morphs into a form of PFOF. This structure unfairly benefits larger
brokers who can afford to trade in larger volumes, creating an
imbalance at the expense of smaller brokers who face additional fees.
These fees end up subsidizing the rebates for the larger brokers,
leading to a market dynamic that favors a few at the cost of many.

The situation is compounded by the rebate system that encourages
brokers to increase their trading volume to gain larger rebates. This
emphasis on quantity over quality can degrade the overall market
competition and efficiency, shifting the market dynamics in a way that
might not serve the best interests of all market participants,
especially individual investors.

In conclusion, the prevalence of PFOF and similar practices within the
U.S. markets is a significant concern that undermines the principles
of fair and efficient trading. It is imperative for those overseeing
market regulations and participants to critically reassess these
practices to ensure a market environment that is both competitive and
equitable for all involved.

Sincerely,

Household Investor