Mar. 12, 2023
To whom it may concern, Order Competition Rule S7-31-22 Every investor, including household investors, should have equal access to the best market prices available in the national exchange system. These prices should be determined by competition driven by market forces and not influenced by PFOF. Market makers should not be able to dictate the entire market as they see fit through manipulations possible in the current market structure. Citadel recommended withdrawing this proposal for a number of reasons, including the unprecedented nature of requiring certain market participants to utilize a specific trading protocol. I would rather pay a commission to avoid sending my orders to a wholesaler to be internalized by any business. Such protocols are damaging to the entire market. Companies such as Citadel should not be in total control of household invested order flow. No company should have advanced information of my trade prior to its execution at open auction. A major concern moving forward with commissions on each order is price gouging from brokers. I recommend establishing a maximum commission per order which brokers are allowed to charge. Analyses estimate that over one billion dollars in savings would passed onto the household invested which would be mainly generated through increased competition to supply liquidity to marketable orders of individual investors. This would have an impact of improved price discovery. Title 15 U.S.C. 78k-1 of the U.S. legal code on the objectives of the SEC recognizes, among many issues, that the securities markets are an important national asset which must be preserved and strengthened. It also recognizes new data processing and communications techniques create the opportunity for more efficient and effective market operations and that it is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure economically efficient execution of securities transactions and fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets. Sincerely, Calvin Nilles