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

Mar. 15, 2023

 


Data shows that the “free” trading actually costs individual investors billions of dollars each year.  Through wholesaling, payment for order flow and off-market trading, individual investor trades rarely effect the price on the lit market. I find this to be Un-American and to run against the “Free and fair markets” line that is touted to the world. I would gladly pay a commission for my trades as opposed to continue with the status quo. I applaud the Commission for taking on this issue and agree with the rule and its language in general and hope for its implementation in short order.  


The parties that this rule would affect have very clear conflicts of interest. I find it to be extremely concerning that a “market maker” can also have a hedge fund wing that can make bets on the very securities they are making markets for. They can clearly put their fingers on the scale to make the security do whatever it is they want it to do. I have seen this in action on many occasions on the securities I am invested in on a daily basis.  


I would take it a step further and state that the idea of a “market maker” is antequated in 2023. There is Zero Knowledge (Zk rolluos) on the ETH L2 blockchain that can handle many orders instantaneously from many different places without anyone knowing who is on the other side of the trade. To me, this is already available and a better method than the current system.  


For now, this is an improvement and I support the rule. Ending payment for order flow, putting all individual trades on the open market and creating competition for those trades will cause more organic price discovery and hopefully end the feeling that I have right now, that the markets are rigged.  


I want to believe in a “free and fair” market, this and other rules do help go towards that, so I applaud the commission in taking these steps.  More will be needed.  


Thanks for your time.  


Chris Duer