Mar. 07, 2023
March 7, 2023 Dear SEC Commissioners, I fully support the proposed rule 615, as it would promote competition and protect the interests of individual investors in the market. The prohibition of restricted competition trading centers from internally executing certain orders of individual investors without exposing them to competition at that price in a qualified auction operated by an open competition trading center would help put a stop to payment-for-order-flow and internalization of orders. This would lead to a reduction in systemic market risk, market manipulation, and improve the conditions of retail investors. I do not support exceptions of any kind here. It is of critical importance that all orders of any kind go through the auctioning protocol. To me, it should make a difference if the order is segmented into random chunks of either integer and/or fractional values: All shares that an order has in it should be subject to the same exact procedure. No differentiation whatsoever, at any point. I believe that exposing segmented orders to competition in qualified auctions would generate better prices for individual investors than current broker-dealer routing practices. This likelihood of better prices may vary across different types of NMS stocks, such as those with different levels of liquidity and trading volume. I also think that the wide dissemination of auction messages for qualified auctions in NMS stocks would be likely to affect trading or quoting behavior in NMS stocks during the time period of the auction, but this effect would promote obtaining the best possible price for segmented orders in the qualified auctions. I believe that the proposed prohibition of display of auction responses would sufficiently mitigate the possibility of information leakage for participants in a qualified auction. The focus on the accounts of natural persons, as well as accounts held in legal form on behalf of a natural person or group of related family members, and the level of trading activity in such accounts is an appropriate approach to identify orders that are included and excluded from the proposed definition of a segmented order. I do not think that the proposed definition of an open competition trading center requiring national securities exchanges to operate as an SRO trading facility that is an automated trading center and displays automated quotations that are disseminated in consolidated market data is appropriate. Preferably, there should not be SROs, there should be outside regulation and audits to ensure compliance. Requiring a minimum level of trading volume for national securities exchanges to qualify as open trading competition centers is an appropriate means to achieve the objectives of Proposed Rule 615. Preferably, the proposed minimum price increment should be at least the 0.1 cents, much more preferably 0.01 cents to level the playing field with other market participants and retail investors. Lastly, open competition trading centers and national securities exchanges should not be allowed to continue to operate trading systems, other than qualified auctions, that are limited, in whole or in part, to the execution of segmented orders and that do not fall within one of the five exceptions in Proposed Rule 615(d)(2) and (g) Thank you for considering my comments. Sincerely, Matthew Gavyn Mutman