Subject: S7-31-22: WebForm Comments from Vincent H. Merrywheather
From: Vincent H. Merrywheather
Affiliation: Professional Commenter

Jan. 03, 2023

January 3, 2023

 Dear Ms. Countryman,

this comment is re: rulemaking proposal S7-31-22 'Order Competition Rule'.

Regrading Title IV., Letter B, Section 5: Exceptions to Rule 615, I suggest to amend the rulemaking proposal in the following manner

The order competition requirement should also apply when a segmented order is received and executed during a time period when no open competition trading center is operating a qualified auction for said order.

Reasoning:
1.) This change would make a small but significant contribution to leveling the playing field between high-frequency trading algorithms and human traders such as individual investors.
2.) Computerized trading should not receive a lighter touch of regulation than trading by humans.

Sincerely,
Vincent H. Merrywheather