Subject: Order Competition rule, file no. S7-31-22, release no. 34-96495
From: Emil Ask
Affiliation:

Mar. 19, 2023

 

Dear SEC  I am an Household investor and I would like to make my voice heard about the rule in question:
The effectiveness of any SEC rule is dependent on its enforcement, so drastically higher fines and seizure of any profits made illegally, as well as jail time, should be implemented to serve as a significant deterrent.Broker-dealers should face license revocation instead of minimal fines that allow them to view such penalties as just a cost of doing business.
The proposed rule to reduce speed games and inducements damaging market integrity deserves prompt implementation. Efforts to reduce the unfair information advantage enjoyed by market participants should be taken by having brokers first route to the auction and specify the order's destination if the auction is unsuccessful.
More transparency is needed in dark markets, so it's good that the rule changes like forcing dark pools to provide quotes and trades to consolidated market data when operating as an auction are being considered.
The SEC needs to ensure fair competition among brokers, dealers, and markets.
The current market state is anti-competitive, and monopolistic behavior is evident among a small group of off-exchange dealers who capture the majority of marketable orders of individual investors.
This proposed rule is a significant step towards creating a fairer market.
The fragmentation of markets benefits dominant players, so a more transparent, simple, and free market structure like the one proposed in this rule is preferred.
The involvement of wholesalers in routing orders is problematic, as they have conflicts of interest, are not transparent, and have been found to execute orders at prices less favorable than the NBBO midpoint. Removing them from the market would lead to significant savings for individuals and institutions alike.
Regards 
Emil A. Frederiksen