Mar. 12, 2023
I am writing in full support of this rule. It is refreshing to see significant efforts by the agency to improve the integrity of our markets. It is great that with this rule we are going to see more competition, because monopolies have taken over our financial markets and these are harming household investors on every step of the way to exploit them as much as possible. The Commission has observed that a small group of six off-exchange dealers receive 90% of marketable orders placed by individual investors in NMS stocks, with two firms capturing 66% of those orders. These percentages are expected to be even higher for certain stocks. This situation indicates that the American markets are not competitive, and this needs to be addressed. The proposed rule is a significant step towards rectifying this unfairness in the market. The importance of fair competition cannot be overstated, and it's encouraging to see the SEC taking action to prioritize genuine competition. Also, the idea that household investors "want" their orders to be routed to wholesalers in general is ridiculous. Many would prefer to pay a higher dollar amount per share in exchange of actually contributing to price discovery and to avoid getting their order handled by a wholesaler like Citadel Securities, which has a significant long record of violating the law. This case especially should raise many eyebrows, because how is not an extreme conflict of interest that a wholesaler / Market Maker like Citadel Securities that controls such a large percentage of order flow, also is allowed to run a hedge fund - Citadel Advisors? Considering that Citadel Securities, NYSE and Charles Schwab have submitted a letter to the SEC that is an extremely watered-down proposal to do the bare minimum in equity market reform is concerning. The involved parties have evident conflicts of interest. Citadel, being the largest customer of NYSE, is a major source of funding for multiple broker-dealers. Moreover, wholesalers hold significant sway over other market players, which raises concerns about their ability to assess these rules impartially. To me, it is evident that eliminating the intermediaries who aim to make excessive profits from the market will result in better prices for both individuals and institutions. In summary I am in favor of the rule. However, I propose one change: The rule permits orders to first go to Citadel Securities, followed by the auction for fair competition. This gives them a considerable information advantage, which I believe should be eliminated.