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

Mar. 12, 2023

 




To whom this might concern:  

As a retail trader, I strongly support the proposed rule to prohibit restricted competition trading centers from internally executing certain orders of individual investors at a price unless the orders are first exposed to competition at that price in a qualified auction operated by an open competition trading center. This rule is essential for protecting retail traders from the unfair and manipulative practices of the larger market makers and high-frequency traders (HFTs). First of all, the proposed rule would protect retail traders from the unfair practices of certain market makers and HFTs. By requiring that orders be first exposed to competition in a qualified auction before they are internally executed, this rule will help to ensure that prices are fair and that market makers and HFTs do not take advantage of retail traders by trading against them without proper disclosure. Furthermore, this rule will prevent market makers and HFTs from manipulating the markets by using their superior speed and access to information to trade ahead of retail traders. Secondly, this rule will ensure that retail traders have access to fair prices. By requiring that orders be first exposed to competition in a qualified auction, this rule will ensure that prices are fair and that retail traders do not pay more than necessary for their orders. Furthermore, the rule will help to prevent market makers and HFTs from manipulating the market by artificially inflating or depressing prices. Finally, this rule will help to increase the transparency of the markets. By requiring that orders be first exposed to competition in a qualified auction, this rule will help to ensure that all market participants have access to the same information and that the markets are not manipulated by certain market makers and HFTs. Furthermore, this rule will require dark pools to become transparent and start submitting data to public feeds, which will help to ensure that the markets are fair and efficient. In conclusion, I strongly support the proposed rule to prohibit restricted competition trading centers from internally executing certain orders of individual investors at a price unless the orders are first exposed to competition at that price in a qualified auction operated by an open competition trading center. This rule will help to protect retail traders from the unfair and manipulative practices of larger market makers and HFTs, ensure that retail traders have access to fair prices, and increase the transparency of the markets.  


The parties involved have very clear conflicts of interest. Companies such as Citadel are a large source of funding for many broker-dealers and is, for example, the NYSE's biggest customer. Wholesalers exercise extreme influence on other market participants and I am concerned that influence will infect the ability of some participants to objectively review these rules. The current market is obviously not fair and this proposed rule is an important step in that direction. Fair competition is incredibly important and it’s good to see the SEC prioritizing true competition. 


Please implement this rule as quickly as possible. 


Best regards, 
Alexander Kuchta, MSc Economics