Mar. 12, 2023
To whom it may concern, As an avid investor in the U.S. stock markets, I fully support this rule as it promotes clarity, fairness and a just market. The current process of a broker sending orders to a wholesaler, who then forwards them to an auction and potentially back to the wholesaler appears overly complicated and confers an unfair informational advantage upon the wholesaler. They can view the orders before anyone else, giving them an edge over other market players. To rectify this situation, the Commission should require brokers to first send orders to the auction and specify an alternate destination if the auction fails. This would ensure equal access to information across the entire market. Furthermore, the presence of monopolies and monopolistic behavior is concerning, as it undermines healthy competition. The Commission has observed that a mere six off-exchange dealers handle 90% of marketable orders for individual investors in NMS stocks, with two of them controlling 66% of the market share. These numbers are likely even more pronounced for certain stocks. This state of affairs within American markets is decidedly uncompetitive and requires rectification. It is evident that certain market players are profiting from a position of dominance that undermines competition in the marketplace. They obtain order flow by paying for it or through behind-the-scenes arrangements. Why is it not possible for orders to compete on an open market? It is encouraging to see that the Commission has finally recognized this issue and subsequently has proposed this rule. I truly hope it passes and is implemented promptly so we can take a large step toward a fair and free marketplace. Regards, Ryan Gilbey