Mar. 12, 2023
Good afternoon I am a household investor, and I would like to submit my comments on the above mentioned rule. I fully support the implementation of the proposed rule, and I commend the bravery it has taken to take a stand against the vast conglomerations of middlemen like this. I would ask for your consideration in further strengthening it by preventing brokers routing orders first to wholesalers, before the auction, as this provides an information advantage to the wholesalers, which is anti-competitive by design. Rather brokers should route orders straight to public auction, allowing for genuine competition, and a level playing field. I would also add that in general, the rules set down are only as good as their enforcement. Whilst fines and settlements remain minimal relative to the profits that rule breaking generates, they will continue to be seen as a cost of doing business. I would advocate for fines being pegged to a multiple of the revenue they have generated, so that they are genuinely punitive, and a true disincentive. Further than that, fines should escalate for repeat offenders, so that "mistakes" are not incentivised to reoccur. Repeated and flagrant flouting of rules and regulations should lead to bad actors losing their licenses, and ability to do business outright, rather than continue to act in bad faith, against the good of the market. Best wishes, and bon courage Jonty Simson