Mar. 19, 2023
Dear Securities and Exchange Commission, I am writing to express my support for the proposed rule, Disclosure of Order Execution Information. As a retail investor, I believe that Best Execution is crucial in ensuring that individual investors receive the best possible execution for their trades. However, without clear guidance and standards, retail investors may not have a deep understanding of the markets, making it difficult for them to interpret the data in Regulation NMS Rule 605 reports. Therefore, I urge the SEC to provide clear guidance on how to read and interpret the data in these reports, especially for retail investors. Brokers must owe their customers a duty of Best Execution derived from common law agency principles and fiduciary obligations. Conflicted orders should not be part of the Best Execution rule. The proposed rule would provide a more detailed and comprehensive standard for broker-dealers to follow, resulting in consistently robust best execution practices. It would also promote transparency and accountability for the broker-dealers' practices through quarterly reviews of execution quality. As recent cases, such as Robinhood's failure to satisfy its best execution obligation and Citadel's internalizing and executing customer trades at less favorable pricing, have demonstrated, the absence of the best execution rule can lead to customers being unaware of revenue arrangements between brokers and subpar trading firms or paying higher transaction prices. Therefore, the proposed rule is a necessary step in protecting household investors and promoting fair and efficient markets. As always, enforcement is the name of the game. I hope there will be severe repercussions for those that do not follow this rule, should it become law. In conclusion, I support the proposed Disclosure of Order Execution Information rule and urge the SEC to prioritize the protection of individual investors by creating a competitive market structure that encourages transparency, accountability, and consistently robust best execution practices. As always, enforcement is the name of the game. I hope there will be severe repercussions for those that do not follow this rule, should it become law. Sincerely, Hussain Shahabuddin