Mar. 03, 2023
March 3, 2023 Dear SEC, I am writing to express my strong support for the proposed SEC rule S7-29-22, also known as the Disclosure of Order Execution Information rule. This rule aims to improve the transparency and fairness of the securities markets by requiring broker-dealers to disclose information about the quality of their order execution to their clients. I believe that this proposed rule is essential to ensure that investors have access to the information they need to make informed decisions about their investments, and that broker-dealers are held accountable for providing fair and efficient order execution services. Disclosure of Order Execution Information: Under the proposed rule, broker-dealers would be required to disclose certain information about the quality of their order execution to their clients. This would include information about the speed and likelihood of order execution, the quality of the prices obtained, and any conflicts of interest that may exist. This information would be provided in a standardized format, making it easier for investors to compare the quality of order execution services provided by different broker-dealers. This would help to promote fair competition among broker-dealers, as investors would be able to choose the broker-dealer that provides the best order execution services for their needs. Benefits of Disclosure of Order Execution Information: The disclosure of order execution information would provide several benefits to investors and the securities markets as a whole. First, it would help to promote fair competition among broker-dealers. By providing standardized information about the quality of their order execution services, broker-dealers would be incentivized to improve the quality of their services to remain competitive in the market. Second, it would help to ensure that investors receive fair and efficient order execution services. By providing information about the speed and likelihood of order execution, the quality of the prices obtained, and any conflicts of interest that may exist, investors would be able to make informed decisions about their investments and avoid any potential harm from subpar order execution services. Third, it would promote market transparency and reduce information asymmetry. Currently, investors may not have access to information about the quality of order execution services provided by their broker-dealers. This can lead to information asymmetry, where some market participants have more information than others. By requiring broker-dealers to disclose information about the quality of their order execution services, investors would have access to the same information as other market participants, promoting transparency and reducing information asymmetry. Potential Challenges and Concerns: While I strongly support the proposed Disclosure of Order Execution Information rule, I acknowledge that there may be some challenges and concerns associated with its implementation. One potential challenge is the cost of compliance for broker-dealers. Compliance with the rule would require broker-dealers to invest in new systems and processes to collect and report the required information. This could be a significant expense, particularly for smaller broker-dealers. However, I believe that the benefits of the rule outweigh the costs. By providing investors with standardized information about the quality of order execution services, the rule would promote fair competition and ensure that investors receive fair and efficient services. This would ultimately benefit the securities markets as a whole. Conclusion: Overall, I strongly support the proposed SEC rule S7-29-22, the Disclosure of Order Execution Information rule. This rule would improve the transparency and fairness of the securities markets by requiring broker-dealers to disclose information about the quality of their order execution services to their clients. By providing investors with standardized information about the quality of order execution services, the rule would promote fair competition and ensure that investors receive fair and efficient services. I urge the SEC to finalize this rule as soon as possible, to protect investors and promote fair competition in the securities markets. Thank you for considering my support for this important proposal. Sincerely, Chris Robinson