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

Mar. 12, 2023

 


To whom it may concern, 


As a concerned investor, I have a few points I would like to address. 


A broker routing orders first to a wholesaler, who then passes them to the auction, which might route it back to the wholesaler, this seems unnecessarily complex and also grants the wholesaler a huge information advantage against other market participants where 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. This would make it fair across the board. 



Additionally, the only punishment given are small fines compared to the amount of profit made by failing to follow the rules. The only incentive this gives is for continuing to break the rules and continuing to profit. The punishment should be much more severe for failing to follow the rules such as loss of licenses or even further. 


This rule should be implemented as soon as possible with a hard deadline. As we know, when people have to work to a deadline, this is when the work gets done. 


Thank you for your time.