Mar. 19, 2023
Good afternoon, As a household investor I have been watching the past few weeks with great horror and humiliation as the powers that control "the free market" consistently and efficiently go out of their way to benefit market makers, short hedge funds, and anyone else that would look to earn money off the backs of Americans time and time again. Here is a list of reasons I support this rule to help curb the death grip entities like Citadel and Co have on the world economy. Support for the new rule that states that Citadel cannot be the first to receive orders; instead, orders must go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order. Payment for Order Flow (PFOF) has been effectively banned in the UK due to conflict-of-interest concerns and this should be the case in US markets too. Brokers who do not accept any kind of PFOF route orders differently and consequently see superior execution quality. A recent study found that Robinhood does not provide statistically significant price improvement relative to exchanges, despite PFOF being responsible for around 70% of its revenue. Retail investors not dealing with PFOF get a better price than those dealing with it, violating FINRA's Best Execution guidance. FINRA İs evaluating the impact of not charging commissions on member firms' order-routing practices and decisions, and the findings should be made public. TD Ameritrade's order routing decisions don't seem to be motivated by competition despite what they state on their website, and they pay to get the first look at orders, routing them to firms that net themselves billions of dollars in the process. Dark pools (Alternative Trading Systems) should provide quotes and trades to consolidated market data to bring more transparency to dark markets. The Commission should address the unfair information advantage of wholesalers by having brokers first route to the auction and specify where the order should go if the auction is unsuccessful. The state of American markets is anti-competitive, and fair competition is essential. The Commission needs to ensure fair competition, especially within the off-exchange systems that currently dominate. Wholesalers exercise extreme influence on other market participants, and there are conflicts of interest that may infect the ability of some participants to objectively revie the rules The list goes on but suffice to say this rule would help the free market become a free market and not the monopoly it currently is. Please consider household investors that are set to lose everything because a few people wanted an extra mansion. Thank you.