Mar. 2, 2023
March 2, 2023 I would like to raise my voice in support of this proposed ruling. I strongly feel that this is a good first step towards repairing our market structure that has become tainted by a perverse incentive to internalize order flow rather than letting it go to a lit market. Internalization and dark-market transaction suppress natural price discovery, and with houshold investors participating in the mark FAR more actively than ever before there is a false perception that household investing and institutional investing can and should be treated differently in routing. Internalizing most of household investors orders while letting institutional orders hit a lit market ( Weighing price discovery in favor of institutional sentiment), creates an incomplete and often misleading picture of actual market sentiment since household investors often utilize different trading strategies than institutions. A more complete picture becomes apparent when retail holds a strong inverse sentiment to institutions and overpowers wholesalers or internalizers ability to continue routing off exchange, causing movements in markets that are largley unexpected by institutions. Allowing payment for order flow incentivises institutions to weigh price discovery in their own favor, causing an even further imbalance in price discovery's reflection of true market sentiment. This opens the door to idiosynchratic and systemic risk for our sintitutions when when household sentiment reaches levels enough to tip the balance back towards true price discovery. Institutions are a vital part of our markets and economy, but household investors are as well. It is high time they are treated as such.