Subject: Re: Order Competition Rule, File No. S7-31-22, Release No.34-96495
From: Chris Burtt
Affiliation:

Mar. 13, 2023

 






To whom it shall concern, 


I fully support the rule, except that I believe that orders should FIRST be routed to auction before being received by firms like Citadel. 


These sorts of rules are only useful with ENFORCEMENT. I want to see massive fines that are proportionate (and in excess of) to the profits gained by institutions that break them and jail time for those; otherwise fines are just a cost of doing business. This also means that broker-dealers should risk losing their licenses when repeatedly in violation of these rules. 

  
This proposed rule is an important step in the direction of having fairer markets. Fair competition is incredibly important and it’s good to see the SEC prioritizing true competition, as competition is BENEFICIAL for household investors.  


 I also agree with the following points which I obtained from reddit.com/r/superstonk: 


"I would gladly pay more per share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government (https://files.brokercheck.finra.org/firm/firm_116797.pdf). 
  
Research heavily suggests that internalization is bad for markets https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4070056 
  
I dislike middlemen that simply exist to get their cut of a transaction that would otherwise occur. I would prefer that money go to pension funds instead of Wall Street Billionaires. 
  
  
It is clear to me how removing the profiteering middlemen from the market will improve prices for both individuals and institutions (e.g. pension funds). Recent research by Hittal Mittesh suggests that on top of the Commission's estimate that the auctions would save individuals from billions of dollars taken by wholesalers, it would also save institutions over $1.5 billion each year. Wholesalers are taking from citizens AND people's pensions - that needs to stop. Citation: https://4982966.fs1.hubspotusercontent-na1.net/hubfs/4982966/BestEx%20Research%20Order%20Competition%20Rule%20Analysis%2020230105.pdf" 

Sincerely, 
Christopher Burtt 
A Concerned Household Investor.