Mar. 12, 2023
I am encouraged by the content of this rule; I am in favor of it and I am grateful for all your efforts to make American markets fair and equitable for household investors like me. * Broker-dealers route more than 90% of marketable orders of individual investors in NMS stocks to a small group of six off-exchange dealers (wholesalers). The wholesaling business is highly concentrated, with two firms capturing approximately 66% of the executed share volume of wholesalers as of the first quarter of 2022. Within certain stocks, that monopoly might reach over 70-80% or higher. A single wholesaler could control almost all the order flow for a particular stock on a given day. Household investors are not given a chance with the market system configured as it is now. FYI: MONOPOLY BAD. Fair competition is essential for a healthy market; orders need to compete for price discovery to happen fairly. Paying commissions on trades seems a fair price to me to gain true price discovery; I prefer paying commissions if I get price discovery. * Orders should be routed DIRECTLY to the auction; orders that are routed first to a wholesaler and then sent to the auction provide the wholesaler with valuable data that they can use to their advantage. Knowledge is power; if a wholesaler has data relating to orders sooner than anyone else that creates an advantage for them. Removing profiteering middlemen from markets is essential for true price discovery. * Order Competition Rule, File No. S7-31-22, Release No.34-96495 must be passed to preserve household investors' faith in the system, and it needs to be enforced with more than a slap on the wrist. Fines currently only represent a 'cost of doing business'; if a participant commits a financial crime, they currently pay a fine that is a minute fraction of their ill-gotten gains and pocket the rest. Guilty participants should be fined double the amount of their transgression and also serve time in prison so as to create a REAL deterrent to white collar crime. The practice of being allowed to pay a relatively small fine without admitting guilt or wrongdoing should be stopped immediately. * Removing the profiteering middlemen from the market will improve prices for both household investors and institutions (e.g. pension funds). Think of the teachers, the firefighters, all the people depending on pension funds to survive when they retire. Wholesalers who participate in payment for order flow are robbing individuals and institutions of their wealth while claiming to help them. Sincerely, Tamula Sanders Household investor, retiree