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

Mar. 12, 2023

 



Hello, 



First and foremost, rules are only as good as the enforcement behind it. The most egregious offenders should lose their licenses instead of receiving a fine. Otherwise, this will remain as nothing more than the cost of doing business. 

  
But as for the rule itself, I fully support its implementation. 


A broker routing orders to a wholesaler, then to the auction, which occasionally routes back to the wholesaler, is unnecessarily complex and grants the wholesaler a ridiculous information advantage compared to other market participants. They get to see orders well before anyone else. The Commission should address this unfair information advantage by having brokers first route to the auction and specify where the order should go if the auction is unsuccessful. That way the entire market has equal knowledge. I would even gladly pay more per share if it meant avoiding being routed through a wholesaler. 

  
Transparency is important for well-functioning markets, and this rule is a good step in that direction. 



Thank you, 





Gordon R.