Mar. 13, 2023
Dear SEC, Effective enforcement is crucial for SEC rules to be impactful. I believe that imposing higher fines and revoking licenses of broker-dealers who engage in unethical practices will serve as a deterrent against such behaviors. I fully endorse the proposed rule and urge its prompt implementation. I support any initiatives aimed at reducing manipulative practices that undermine the integrity and functioning of US markets, such as prohibiting inducements and eliminating the unfair information advantage gained by wholesalers. The current system, where orders are routed through a series of intermediaries, creates unnecessary complexity and hinders transparency, giving some players an unfair edge over others. The Commission should require brokers to route orders directly to the auction and specify alternative routes if necessary to level the playing field. Fair competition is a key principle in US securities markets, but the dominance of a few off-exchange systems has created a monopolistic environment that harms investors and undermines market integrity. The proposed rule is an important step towards restoring fair competition and increasing transparency in dark markets. The SEC needs to be more vigilant in ensuring that brokers and dealers operate within a level playing field. I would rather pay a higher fee per share than have my orders routed through wholesalers that have been repeatedly charged with violating securities laws. These wholesalers have significant conflicts of interest and wield undue influence over other market participants. Studies have shown that internalization harms market quality and results in poor execution for investors. By removing profiteering middlemen from the market, individuals and institutions can benefit from improved pricing and billions of dollars in savings. The proposed rule seeks to simplify and enhance transparency in US markets by eliminating intermediaries, reducing fragmentation, and preventing monopolistic practices. I support this initiative as it aligns with my preference for a free and transparent market structure that benefits all participants, not just a few dominant players. U.S.C. 78k-1 (“section 11A”) states that "It is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure ... fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets." Thank you, Greg