Mar. 19, 2023
Dear SEC, I am writing to express my strong support for the Order Competition Rule. Orders must go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order, rather than being sent directly to specific market makers. The Order Competition Rule would prevent conflicts of interest and ensure a level playing field for all market participants. It would prevent market makers from receiving preferential treatment, which could lead to unfair advantages and create conflicts of interest that undermine the integrity of the market. Furthermore, the Order Competition Rule would provide greater transparency and accountability in the market, as all market participants would be able to see the bids and offers available in the auction. This would help to ensure fair pricing and prevent manipulation. Recent studies have found that brokers who do not accept any kind of payment for order flow route orders differently and provide superior execution quality. In addition, retail investors not dealing with payment for order flow get a better price than those dealing with it, which violates FINRA's Best Execution guidance. In conclusion, I believe that the Order Competition Rule is essential to ensure fair competition and protect the integrity of our markets. I urge you to implement this rule to ensure that all market participants have an equal opportunity to compete. Sincerely, Cody Horton