Mar. 19, 2023
Hello Ms. Countryman, I am writing in support of the proposed Order Competition Rule. I believe market transparency should be maximized as it inherently promotes competition, efficiency, and minimizes potential risk of price dislocation. It also inherently stifles conflicts of interest among brokers and wholesalers. I think the majority would benefit from a market that seeks transparent bids for execution to guide order flow rather than opaque incentives associated with ATS as they currently operate. ATS should not function as a black box and should be subject to increased regulatory scrutiny. The incentive for fraud and abuse is too high for internalized trading systems to continue operating as they do today. Policies should be created to ensure ATS are operating within the same regulatory framework that guides the broader market. This should include real time data on order execution, order routing, and usage of dark pools being available for scrutiny by the SEC. There should not be a material difference in price between dark and lit trades. Inadequate regulation could foster a situation where real prices are available only to large entities and a parallel dislocated lit market could be maintained through leverage and internalized order flow. This would create unnecessary fragility and would damage the credibility of our markets and should not be allowed. I support this proposed rule and will support all changes that promote transparency and competition, align incentives to improve stability and resilience, and reduce potential for fraud. Thank you, Lee Cunningham