Mar. 19, 2023
Dear SEC, I am writing to express my support for the proposed Order Competition Rule (File No. S7-31-22). The implementation of this rule is crucial for promoting a fairer and more transparent stock market by increasing competition among different trading platforms and ensuring that brokers and wholesalers operate transparently and honestly. The SEC should focus on reducing conflicts of interest by improving transparency in the routing of orders by brokers and wholesalers, allowing investors access to the best-priced quotations available in the NMS. The proposed changes to ATS rules that promote better alignment with regulatory frameworks for exchanges would benefit individual household investors. ATS should submit detailed disclosures about their operations, including conflict of interest management, order routing practices, and customer order handling. This will make it easier for investors to understand how ATS operate and how their orders are executed. Additionally, ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices, protecting individual investors from abusive practices in the ATS market. ATS should provide detailed information about their systems' operation to the SEC, including data on order execution, order routing practices, and dark pool usage. This will improve the SEC's ability to oversee ATS and ensure compliance with regulatory requirements. ATS should operate consistently with the broader regulatory structure of the securities markets, promoting fair and transparent trading practices that benefit individual investors. Implementing a variable minimum pricing increment model for both quoting and trading of NMS stocks across trading venues is essential for ensuring a level playing field for all investors. Household investors support initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. Sending orders to a wholesaler for internalization should not be the only option available to investors. The SEC should consider implementing a cap on commissions or fees charged by brokers in lieu of PFOF. The potential savings for retail investors, estimated between $1.12 billion to $2.35 billion, could be achieved primarily through increased competition to supply liquidity to marketable orders. Competition in the marketplace is necessary for better market regulation, and barriers to competition, such as the conflicted nature of PFOF, should be removed. The SEC should prioritize creating a competitive market structure that benefits investors and encourages transparency. Thank you for considering my input on this important matter. Sincerely, Robert Alexander Waelder from Gainesville Florida