Subject: S7-31-22: WebForm Comments from andrew gatley
From: Andrew Gatley
Affiliation: Civil Engineer

Dec. 28, 2022

December 28, 2022


I am writing as a retail investor to show my support for this proposal. True price discovery hasn't existed in our capital markets for years, as market makers internalize vast swaths of orders, only sending orders to the lit market they want to adjust the price. Want to increase the price to make your options move into the money? Internalize all sell orders while sending all buy orders to the lit exchanges. Want to drive the price down? Internalize all buy orders and send the sells to the lit exchanges.  Order competition is crucial to bring back price discovery.

One of the most important parts of this fraud is the market makers ability to impact and control the NBBO. Providing infinite liquidity within an NBBO that they control absolutely destroys true price discovery. I am very pleased to see some real changes being proposed, but I would like to see many more.

The market maker exemption to sell short without a locate needs to be abolished. The ability to fail to deliver on trades when receiving customer payment needs to be abolished. No market maker should be allowed to also have a hedge fund. Everything that FTX has done - Citadel and Virtu have done. Just with our traditional supposedly regulated and protected markets. For too long the regulation has served to protect these career criminals, and not prosecute them. Fines need to be larger than profits made, and criminals need to go to prison. Businesses need to lose their licenses. American workers, business owners, and pensioners are having their quality of life stolen from them simply because they participate in America's capital markets. The scam needs to end. Please bring price discovery back to the market. I believe that this proposal is a step in the right direction.