Mar. 19, 2023
I am writing to express my support for the proposed regulation. As an individual investor, I understand the complexities involved in choosing how to execute a trade, which is why I believe that best execution is crucial in trade execution. I urge the SEC to prioritize the protection of household investors by ensuring that brokers are held to a higher standard when executing trades. Clear guidance on how to read and interpret the data in Regulation NMS Rule 605 reports is crucial, especially for retail investors who may not have a deep understanding of the markets. It is important that these reports are easily accessible and understandable to help investors make informed decisions. Brokers owe their customers a duty of Best Execution derived from common law agency principles and fiduciary obligations, and I strongly believe that it should become a rule that the SEC can enforce. Conflicted orders should not be allowed in a Best Execution rule. It is vital that investors are aware of revenue arrangements between brokers and subpar trading firms to avoid paying higher transaction prices. Different trading venues may offer different prices, and slower execution can lead to missed opportunities. Information leaks can inhibit a successful transaction, and less reliable settlement processes can delay receipt of proceeds. Quarterly reviews of execution quality would provide transparency and accountability for the broker-dealers' practices. The recent cases involving Robinhood and Citadel highlight the importance of Best Execution. Brokers who fail to satisfy their best execution obligations can cause significant losses for their customers, and misleading statements and non-disclosure of payments received for routing trades to specific firms should not be tolerated. In conclusion, I believe that the proposed regulation is a necessary step in protecting household investors and promoting fair and efficient markets. It will provide a more detailed and comprehensive standard for broker-dealers to follow, resulting in consistently robust best execution practices. I urge the SEC to adopt this rule to ensure that household investors receive the best possible execution for their trades. Thank you for considering my comments. Sincerely, Leonard Ford