Feb. 24, 2023
February 24, 2023 I am writing to express my strong support for the Securities and Exchange Commissions (SEC) proposed amendments to the disclosure requirements for order executions in national market system (NMS) stocks. The proposed amendments seek to update and improve the existing disclosure requirements to ensure that investors receive accurate and useful information about the quality of their order executions. The proposed expansion of the reporting entities subject to the rule requiring market centers to make monthly execution quality reports available to the public is a crucial step towards ensuring that more investors have access to important execution quality information. By modifying the definition of covered order to include certain orders submitted outside of regular trading hours and certain orders submitted with stop prices, the proposed amendments would also provide more comprehensive and accurate information about order executions. I also support the proposed modifications to the information required to be reported under the rule, including the capture of execution quality information for fractional share orders, odd-lot orders, and larger-sized orders. The proposed modifications to reporting requirements for non-marketable limit orders (NMLOs) would also capture more relevant execution quality information for these orders. By eliminating time-to-execution categories in favor of average time to execution, median time to execution, and 99th percentile time to execution, each as measured in increments of a millisecond or finer, the proposed amendments would better reflect the speed of the marketplace. Finally, I strongly support the proposal to enhance the accessibility of the required reports by requiring all reporting entities to make a summary report available. This would ensure that investors can easily access important information about the quality of their order executions. In summary, I believe that the proposed amendments to the disclosure requirements for order executions in NMS stocks are an essential step towards improving transparency and accountability in our markets. I strongly encourage you to support these proposals and work to ensure that they are implemented effectively. Thank you for your time and attention to this important matter.