Mar. 12, 2023
SEC: Please implement this rule expeditiously. I support this rule. Directly from US Code Law: U.S. Code § 78k–1 - National market system for securities; securities information processors (1) The Congress finds that— ... (C) It is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure— (i) economically efficient execution of securities transactions; (ii) fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets; (iii) the availability to brokers, dealers, and investors of information with respect to quotations for and transactions in securities; (iv) the practicability of brokers executing investors’ orders in the best market; and (v) an opportunity, consistent with the provisions of clauses (i) and (iv) of this subparagraph, for investors’ orders to be executed without the participation of a dealer. I believe this rule would move the market towards fair competition between broker dealers and simplify market structure. Currently, the rules benefit the dominant entities when they pay for order flow. Payment for order flow does not ultimately benefit the public interest. These dominant entities (hand full of off-change dealers) are now, basically monopolies: controlling a majority of orders. The current market structure is not fair and lacks competition. All orders should first complete on lit exchanges - in the light of fair auctions in public view. The reduction of middlemen in our markets will reduce the fees (apparent or otherwise) and investment in our marketplaces should be maximized. Compounding fees are too often hidden in costs not transparent to the investor. These hidden fees include: large rebates for the order flow, bad execution prices, unbalanced order flow knowledge and a high frequency infrastructure advantage by off-change wholesalers. Along with this rule, please provide the market infrastructure for prompt, transparent and expeditious enforcement (along with fees equal to damage) for and to support the rule. -- Regards, Joshua J. Fenske, PE, SE