Mar. 19, 2023
Dear fellow market observers, As we continue to assess the current state of American markets, it has become increasingly clear that fair competition is essential for the success and stability of our financial system. Unfortunately, we have seen a significant shift towards anti-competitive practices in recent years, particularly within the off-exchange systems that currently dominate the market. In light of these concerns, it is imperative that the commission take action to ensure fair competition and address the unfair information advantage of wholesalers. One key approach to achieving this goal is through the implementation of the Order Competition Rule. Under this rule, brokers would be required to first route orders to an auction, which would provide an opportunity for fair and open competition among market participants. If the auction is unsuccessful, brokers would then be required to specify where the order should go, which would help to prevent unfair advantages for certain market players. Furthermore, I believe that Payment for Order Flow (PFOF) should be banned in the US markets. While this practice may appear to offer benefits for investors, there are serious conflict-of-interest concerns that cannot be ignored. By eliminating PFOF, we can help to ensure that all market participants are treated fairly and that the market operates in a truly competitive and transparent manner. Overall, I strongly support the Order Competition Rule as a key step towards ensuring fair and open competition in the American markets. I urge the commission to take action on this critical issue and work towards a financial system that is equitable and sustainable for all. Thank you, Cassie Wendland