Mar. 12, 2023
Dear SEC, I am a european household investor that is invested in an american company. The decisions you make directly concern me, my family and my investment. Here are our thoughts on "Order Competition Rule, File No. S7-31-22, Release No.34-96495" Please implement the rule as soon as possible. However, it's important to note that the effectiveness of this rule depends on the enforcement that backs it. Higher fines are necessary to serve as a significant deterrent, and some broker-dealers should lose their licenses rather than receiving fines that are merely a cost of doing business. This will discourage ill-gotten gains obtained through "honest mistakes". I believe that the current practice of routing orders first to a wholesaler, who then passes them to the auction, which may route them back to the wholesaler, is overly complex and grants the wholesaler an unfair information advantage over other market participants. The Commission should address this by having brokers first route orders to the auction and specify where the order should go if the auction is unsuccessful. This will ensure equal knowledge for the entire market. I fully support rule changes that bring more transparency to dark markets, such as the current rule that forces dark pools to provide quotes and trades to consolidated market data if they wish to operate as an auction. The investing public deserves easy access to information about what is happening within the markets. Section 11A states that it is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure fair competition among brokers and dealers, exchange markets, and markets other than exchange markets. It is good to see that the Commission is beginning to take its mandate more seriously, especially within the off-exchange systems that currently dominate. The state of American markets is clearly anti-competitive, as evidenced by the fact that 90% of marketable orders of individual investors in NMS stocks go to a small group of six off-exchange dealers, and 66% is captured by just two firms. This needs to change. There are clear instances of monopolistic behavior among some market participants, who benefit from a dominant, anti-competitive position in the marketplace. Orders should compete in lit markets, and the proposed rule supports this. The proposed rule presents a more simple, transparent, and free market structure, which I prefer over the current fragmented market system that benefits only large, dominant players. I disagree with Citadel's proposal and would rather pay more per share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. The conflict of interest between Citadel and other market participants, as well as Citadel's history of flouting the law, raises concerns about objectivity in reviewing these rules. Middlemen that simply exist to get their cut of a transaction are not beneficial, and I would prefer that the money go to pension funds instead of Wall Street billionaires. Wholesalers taking billions from individuals and institutions and calling it "superior performance" needs to stop. Removing the profiteering middlemen from the market will improve prices for both individuals and institutions and save citizens and pensions billions of dollars each year. Thank you for reading and hopefully improving the state of the market. Sincerely, Denis Biko