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

Mar. 15, 2023

I fully support the rule, please implement it as soon as possible with one exception that brokers need to route to auction first before routing anywhere else.  The Commission should address this unfair information advantage by having brokers initially route to auction and specify where the order should go if the auction is unsuccessful. That way the entire market has equal knowledge. I support free and fair markets. 

I fully support and appreciate rule changes like this that bring more transparency to dark markets. The investing public should have easy access to what is happening within the markets to include dark pool (Alternative Trading Systems) 

I believe monopolies are not in the spirit of a free market and our market is moving toward that direction.  The Commission notes 90% of marketable orders of individual investors in NMS stocks to a small group of six off-exchange dealers, and 66% is captured by just two firms. Those figures will be even higher for specific stocks. The state of American markets is clearly anti-competitive and that needs to change. 

15 U.S.C. 78k-1 (“section 11A”) states "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." For too long the Commission has not be enduring fair competition, especially within the off-exchange systems that currently dominate. It's good to see they are beginning to take their mandate more seriously with this rule. 

I would gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. I dislike middlemen that simply exist to get their cut of a transaction that would otherwise occur. 

The parties involved have very clear conflicts of interest. Citadel is a large source of funding for many broker-dealers and is, for example, the NYSE's biggest customer. Wholesalers exercise extreme influence on other market participants and I am concerned that influence will infect the ability of some participants to objectively review these rules. 


Thank you. 
Stephen Abang