Mar. 12, 2023
Each rule that is passed by the SEC must be enforced. I want to see a future where markets are fairer. One where the fines placed for rule breaking are not merely a cost of business. Broker-dealers need to lose their licenses, not merely receive a small fine (in comparison to what they make on their operations) so that our markets can be better for the masses, not the few elite. I fully support the rule. I wish to see it implemented as soon as possible. I appreciate the support and efforts being done to aid in the fixing of the American economy, but it is not nearly fair or equitable yet. I support all efforts that helps to reduce inducements that also reduce the ‘farming’ of individuals’ orders for rebate money. When a broker is routing orders to a wholesaler first, who then passes said orders to the auction, who then may or may not route them back to the wholesaler, this grants the wholesaler an informational advantage which goes against other market participants. This should not be the case. When they see orders before anyone else, that is not an advantage of doing business, that is in its purest form, market corruption. The SEC needs to address these unfair informational advantages. Having brokers first route to auction and to specific where an order should go to if said auction is unsuccessful is one way this can occur. In that way, the entire market will have equal knowledge, as should be the case in a free market. The current rulings force dark pools (Alternative trading systems) to allow for trades and quotes to be consolidated with market data if they wish to operate as an auction, therefore I fully support for there to be rule changes and to have transparency for the market, especially around dark pools and the dark market. The public investors not only should, but need to have access to all information and the happenings within the market. Monopolization of markets is not only bad for the average American, but it is unjust. The Commission makes a note that roughly 90% of all marketable orders of the individual investor base in NMS stocks to the small group of off-exchange dealers and that 66% of this is captured by two firms. This is unjust. The current state of American markets is inherently anti-competitive and this needs to be addressed and changed. The proposed rule is a vital step in the right direction. Fair completion is vital for the American citizens. There are some market participants and firms that are benefiting from dominating, suppressing, and taking advantage of the average American investor, while having an anti-competitor position in our markets. With shady back rooms deals, these participants and firms are paying for order flow and securing it. Why is it that orders cannot compete in lit markers? They need to and they should. It is time the Commission realizes this fact. The fragmentation of the markers makes things vastly over complicated that only benefits the dominant parties. A more simple and transparent free market structure must be enforced and adhered to, such as the one proposed in this rule. I, as a participant of the American markets would be more than happy to pay more per share to avoid the orders being routed through the wholesaler that has been charged for illegal activities over seventy times by the United States government. I would be more than happy to pay commission and avoid being routed through said wholesaler, certainly ones that have an illegal record of breaking rules and regulations and hurting the average investor for profit such as Citadel Securities. Citadel, being a large funder for many of these broker-dealers is the NYSE’s biggest customer. Even so, they should not be allowed to get away with rule breaking. I am concerned by the influence wholesalers have as they have immense amounts of influence on other market participants and therefore have the ability to change the rules to benefit their unjust business practices. Internalization is bad for markets and a plethora of research backs up these claims. Wholesalers are lying. They are lying about the quality of their services so they can profit at the expense of the retail trader. The Commission’s analysis of the CAT data in the infra Table 29 found that 51%, on average, of the shares of individual investor marketable orders are internalized by these wholesalers and then executed at prices that do not favor the individual investor. This is wrong. These middlemen merely exist to get a cut of transactions and this is something that bothers me, as an individual investor. Data clearly showcases that these wholesalers are leaching billions from American individual investors and institutions for profit, while adding no discernible benefit to our markets and the system. Removing the middlemen from the market will clearly benefit both individual investors, institutions, and pension funds to name a few. Wholesalers are a leach on our system and they need to be stopped before they bleed the American public dry. Best regards, An Individual Investor, Oliver