Subject: S7-31-22: WebForm Comments from Abraham
From: Abraham
Affiliation:

Mar. 14, 2023

March 14, 2023

 Dear Ms. Countryman,

As a household investor, I would like to express my gratitude for your efforts to promote competition and transparency in the market. Thank you for providing an opportunity to comment on the proposed changes.

The recommended enhancements are a significant overhaul to the U.S. equity market structure, possibly one of the most substantial changes since the implementation of Regulation NMS in 2005.

Investors should have the right to access the best-priced quotations available in the national market system, which should be determined by competitive market forces. It is unacceptable for anyone to pay billions of dollars for retail orders to control the entire market.

Citadel has recommended withdrawing the proposal due to the unprecedented requirement of using a specific trading protocol. I would rather pay a commission than send my orders to a wholesaler like Citadel, who has been front-running customer orders since 2006 and should not have a monopoly on retail order flow.

My only concern is that brokers may charge excessive commissions or fees to replace PFOF. Therefore, I suggest imposing a cap on the amount of commissions or fees brokers can charge.

I trust the Economic Analysis conducted by the Commission and look forward to potential savings of $1.12 billion to $2.35 billion in transaction costs for retail investors. These gains would be achieved through increased competition in supplying liquidity to marketable orders for individual investors, ultimately resulting in lower transaction costs for individual investors, improved order execution quality for institutional investors, and better price discovery.

Thank you for your attention to these matters.