Mar. 12, 2023
This rule must be implemented and enforced. SEC rules are useless if not enforced. Joke fines, like the ones we have historically seen are NOT a deterrent. Fines have to EQUAL X 2 the total amount of fraud. If that destroys the criminals by their own activity, that is the BEST outcome. All orders must go to AUCTION first, and ONLY to Wholesalers IF no bids are offered. IF the orders go to Wholesalers first, they will profit from the information, and take advantage by internalizing the order. This is simply stealing, as has been going on for years IF Alternative Trading Systems want to participate in/as an auction, they SHALL be forced to provide quotes and trade information to the market data consolidation. This will bring needed transparency to the “unlit” markets (also known as “Dark Pools”) where more than 75% of all trades happen without affecting the lit price. This is WRONG and contrary to the SEC’s main mandate of protecting the Retail Investor. The SEC is bound by 15 U.S.C. 78k-1 (section 11A): “It is in the public interest and appropriate for the the protection of investors and the maintenance of fair and orderly markets to assure … fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets.” The SEC has NOT nor has EVER followed this mandate. These new rules will help. It is truly criminal that the SEC is complicit in allowing large Wholesalers to illegally manipulate the system to steal money from retail investors. Mr. Madoff went to prison for doing this. There are plenty of cells available for Wholesaler C-Suite staff, as well as SEC staff to join them. The SEC shall implement systems to eliminate “Monopolies” within the market system. Monopolies are Anti-Competitive and Criminally Illegal. Any trade that is routed through a market that is “dark”, whereby the trade has no influence on the share price is morally WRONG, and probably Criminal. The SEC must shut down ALL activity in any market that operates outside the transparency of the lit markets. Removing Middlemen/Wholesalers from the trade routes will benefit ALL retail investors, and ALL institutions who hold stock on behalf of others, with BILLIONS of dollars saved every year. This is money taken from Retail Investors’ pockets, AND from the pension funds of hard working citizens around the world, not just in the U.S. PFOF (Payment For Order Flow) is simply a way to STEAL money from investors. It must be eliminated from the system. Brad Hengen Prince Albert, Sk Canada Retail Investor