Subject: S7-31-22: WebForm Comments from Steven R Miller
From: Steven R Miller
Affiliation: Concerned American Citizen

Feb. 24, 2023

February 24, 2023

 My name is Steven Miller and I am an individual household investor.  I am deeply concerned about the American Financial markets, specifically about the potential for financial crimes surrounding Gamestop common stock.

I am writing today to express my support for S7-31-22 Order Competition Rule. I agree with the commission that a restricted competition trading center should not be able to prioritize the internalization of order execution. In fact I believe that restricted competition trading centers should not be able to internalize orders at all, due to the inherent conflict of interest.

I disagree with the commission in paragraphs (b)(2) and (b)(3) specifically around the exceptions for larger ($200,000+) orders and orders that are at favorable prices for individual investors.  Once again, I believe there should be no exemptions or exceptions at all, and that the internalization of orders has an inherent conflict of interest as it eliminates competition. How can a market be free and how can a market be fair in the absence of competition? I realize that, in the oligopoly of broker-dealers that currently exist in the financial markets, avoiding internalization altogether is likely not possible.  In that instance I do agree with the commission in that if internalization is unavoidable, it must be the last resort and competition must be sought out first - whether by qualified auction or competing broker-dealer.