Subject: S7-31-22: WebForm Comments from Trity
From: Trity
Affiliation: Ferou

Mar. 19, 2023



 March 19, 2023

 Ensuring orders go to an external auction before being executed is very important in keeping US capital markets equitable. Competition must be welcomed by all market participants internalized order flow within SROs has created a black hole of transactions by monopolistic market makers.

This ability for internalization creates moral hazard, conflicts of interest, and markets which have no significant oversight or risk mitigation. Continuing to let market makers use pfof, ATSs, and dark pools creates idiosyncratic risk in global markets as those who would commit fraud can do so much more easily.