Subject: Order Competition Rule, File No. S7-31-22, Release No.34-96495
From: Micah Ross
Affiliation:

Mar. 12, 2023

 


I support the proposed rule. Please implement it, albeit with a key modification: The rule as currently written allows for orders to go to market makers first and only then to the auction, which constitutes fair competition. This workflow still gives market makets an informational advantage over retail. Brokers should first route to the auction and only then, if the order is not taken, should the order be routed to the market maker. 


Rules are only as good as the enforcement that backs it. I want to see fines that are a significant deterrent, like fines which are the 500% of profits, employed in South Korean markets. To this, I would add that broker-dealers regularly in violation of rules should lose their licenses.