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

Mar. 12, 2023

 






I fully support this rule and wish it to be implemented as soon as is feasibly possible. 


To whom it may concern: 

My name is Benjamin Ryle, and I currently possess a master's degree focused in the field of Computer Engineering. 

One may call me an ASIC design engineer, but my fields of study are random systems, signals, processes, and the creation of digital circuits which are compliant to analogue requirements. I'm currently an employee of Nvidia, and a founding member of a small medical devices company which applies signal processing techniques to biological signals. This makes me a mid level expert in areas pertaining to the transmission of information, and proper processing of random signals and systems. 


The record profits reported from market makers during a time in which the financial world at large is otherwise suffering has led me in the past year to study the methodologies and systems built to handle the payment for order flow. On even the most surface level, it should be transparent to all involved that there should be at least 1 fundamental tenant to financial systems: "There should be no gain without risk taken up by parties". However, market makers have been touting record profits both in times where markets are doing well, and in times when markets are suffering. 

If it took me with requisite industry experience and education close to 6 months to go from confusion at record profits to believing that market makers are syphoning from household investors. It is because of this that I believe this stands as a regulatory failure, and that the SEC must step in and fix the outstanding conflict of interest between household investors and market makers. 

It should be transparent to all that market makers will continue to make record setting profits every quarter until this syphoning of household investment funds ceases, and therefore I firmly support any attempt to make markets and order flow more transparent, as I would jump at any chance to understand why and how this market failure is allowed to exist with no regulatory intervention, and would love the opportunity to create open research on market order fulfillment. 

Thank you for your time, 
Ben.