Subject: S7-31-22: WebForm Comments from Steven J. Lamb
From: Steven J. Lamb
Affiliation: Retired. Individual Retail Investor since 1997

Feb. 4, 2023

February 4, 2023

 I am a retail investor who has actively traded since 1997.  I have benefited greatly from the elimination of commissions on trading at most retail brokerage firms, first started with Robinhood and then massively helped by such commission free trades at Schwab, TD Ameritrade and others

I have read many of the public comments thus far and there feels like no sense of how much \"free commissions\" have made low cost investing and stock trading available to anyone. My fear is this populist view about \"lets stop the market makers and brokers from fleecing us\" misses the massive gains made by retail traders since 1997 when I first started buying individual stocks and ETFs. My fear is that the the changes proposed may undo some of those massive benefits.

I know the proposed changes are intended to be well intentioned for individual investors  As the saying goes \"the road to hell is paved with good intentions\".  I think if changes are made they should be done incrementally and tested to make sure they work and do what it intended and do not harm the retail investor more than they help. A proposal requiring 400 pages seems excessive and rife with causing more issues than it fixes.

In 1999, I spent over $25,000 on retail trading commissions. Twelve years later In 2011, I spent less than $10,000 even though I had traded 4 times more than what I traded in 1999, through actively seeking low commision platforms.

In 2022 I spent $0 even though I traded more than 1999 and 2011 COMBINED I did 99%+ of my 2022 orders using limit orders that gave me the price I wanted and more often than not slightly improved upon the limit order price.

So I have not just seen progress in trading since 1997 - but rather I have seen progress  so massive and material in nature that it often stuns me.  That progress has been led by an SEC that done all it could to protect individual investors while also incentivizing brokers and other market participants to lower the costs to retail investors.  These are improvements that the SEC and all market participants should be proud of.

If retail investors or others think that exchanges are somehow better than market makers - well the disastrous open of the NYSE on January 24, 2023 should remind us all, that exchanges are not somehow pure or perfect just because they do not take payment for order flow. The idea that one random employee in Chicago forgetting to flip a switch can cause such massive chaos in the financial markets and cause thousands of trades to be unwound and cost other traders lots of money should give us all great concern about forcing trading volume to such exchanges.

Thus I close with this simple request to the SEC - Please consider massively reducing this proposal to more incremental change.  With time and experience, then rules can be further modified and additional rules can be added.  But a 400 page massive upheaval of the best financial markets in the world feels to me like it is likely to cause more problems, costs and harm through reinstating retail trading commissions than it's likely to solve and frankly this proposal has me very nervous. Please strongly consider a much more measured and incremental change so that the Commision can be sure that proposed rule changes are certain to cause far more good than any unforeseen costs and problems that may accrue to retail investors by such a massive proposed upheaval of the greatest financial markets in the world.