Subject: File No. S7-31-22; Release No. 34-96495: Order Competition Rule
From: Siddharth Ravuri
Affiliation:

Mar. 19, 2023

 





Enforcing SEC rules is crucial for their effectiveness, and higher fines should serve as a stronger deterrent to misconduct. Rather than receiving negligible fines, some broker-dealers should lose their licenses for engaging in unethical practices that undermine market integrity.
I fully endorse the proposed rule and urge its prompt implementation. It is essential to curb unfair practices that harm the credibility and functioning of American markets.
Reducing market games and limiting inducements and 'farming' of individuals' orders for rebate money are positive steps toward creating a more level playing field. Brokers routing orders to a wholesaler, who then passes them to the auction, creates unnecessary complexity and unfair advantages for certain market participants. Routing orders first to the auction and specifying the next step if unsuccessful would ensure equal knowledge across the market.
The SEC's efforts to bring more transparency to dark markets are praiseworthy. The investing public should have easy access to information about market activity.
Fair competition is vital for protecting investors and ensuring a fair and orderly market. The Commission's commitment to promoting competition among brokers and dealers, exchange markets, and markets other than exchange markets is commendable. The current market is too dominated by a small group of off-exchange dealers, and monopolistic behavior needs to be addressed.
The proposed rule is an important step toward creating a fairer and more competitive market. Orders should compete in lit markets, and a more straightforward, transparent, and free market structure would benefit everyone.
Wholesalers with a history of violating the law should be avoided, even if it means paying higher fees per share. Their conflicts of interest and influence on other market participants are concerning. Internalization is harmful to markets, and wholesalers are misrepresenting their services to maintain their profits. Removing profiteering middlemen from the market would improve prices for individuals and institutions, redirecting the savings to citizens and pensions instead of Wall Street billionaires.