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

Mar. 12, 2023

 


To any parties of interest, 


As a concerned household investor, I am concerned about the freedom and competitiveness of our markets. The current structure of the markets allows current, unelected middlemen to benefit off of order flow because of the current payment for order flow system. The proposed rule in question would allow for a competitive and free market for order flow, rather than the current almost mercantilist system where designated parties control the overwhelming majority of order flow by matter of the rules. Allowing for a free and competitive market on these trades would allow the best price per trade for participants. Even beside the current system not necessarily even lining up with our conception of liberal free market economics, it is also, in a practical sense, rife for abuse. The ability for orders to be routed allows for the prevention of price discovery via dark pools and other exchanges in a manner that could benefit the appointed party. In that sense, this rule would also block an existing avenue of perverse incentives and corruption by spreading out the distribution of order flow controllers across a larger number of broker-dealers. Overall, this proposal to the rules is sorely needed by the markets, as the current rule is undemocratic and deceptive.