Dec. 29, 2022
December 29, 2022 Dear Securities and Exchange Commission, We are writing to express our strong support for the proposed amendments to update the disclosure required under Rule 605 of Regulation NMS for order executions in national market system stocks. We believe that these amendments will greatly benefit individual investors and the market as a whole by increasing transparency and promoting competition. One key aspect of these amendments is the expansion of the scope of Rule 605 to include broker-dealers with a larger number of customer accounts, single dealer platforms, and entities that would operate qualified auctions. This will ensure that a wider range of entities are held to the same high standards of execution quality, improving fairness and transparency for all investors. We also welcome the updates to the scope and content of the standardized monthly reports required under Rule 605. The inclusion of new statistical measures, such as average effective over quoted spread and average size improvement, will provide valuable insights into the execution quality of different types of orders and help investors make more informed decisions. Additionally, we believe that the proposed amendments will help address some of the negative impacts of payment for order flow (PFOF) and the use of dark pools on the market. By requiring entities that engage in these practices to disclose more detailed information about their execution quality, investors will have a clearer understanding of the potential conflicts of interest and be better able to evaluate the fairness of the prices they receive. Sincerely, Stephen