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

Mar. 12, 2023

 


Hello 


On consideration SEC enforcement should see greatly increased fines that actually serve as a significant deterrent - rather than a cost of doing business. They should be consulate to the profits of the company. 
  
In particular circumstance broker-dealers should forfeit licenses as alternative to fines perhaps implement a 3 strike rule to insure agains “honest mistakes”. Incompetence is sometimes just as damaging as malice.  
  
The Order Competition Rule, File No. S7-31-22 is absolutely essential for fair and orderly markets and should be immediately implemented. 
  
Any king of PFOF or order farming is no better than front running or insider trading and should be stopped with immediate effect. I can’t think of a more damaging practice for stifling price discovery 


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. Equal knowledge is a must for a fair and balanced market. 
  
Also there needs to be much more transparency and clarity with regard  to dark markets. Again a hinderance on price discovery. 
  






Elfed Alexander Morris