Mar. 20, 2023
Dear SEC, I am writing to submit my comments on S7-31-22. A fair market. Real competitiveness where actors have equal chances to provide the best price possible is what makes it reliable, trustworthy, and definitely more efficient. Ans so, fair. That's why, I fully support those new rules that the SEC would like to implement and specifically the one about: Order Competition. Enabling a public auction will provide equal knowledge and transparency for the entire market, which is the very basic of a fair game I would say. We are aware that the PFOF (payment for order flow) is supposedly improving price and creates "affordable trades". But this has not been confirmed or proven at all regarding the price improvement. I wouldn't mind paying the appropriate fees and be assured that my order is not internalised/executed off-exchange and that all participants had equal visibility and decision making regarding my order. It also highlights the question of conflict of interest, it is impossible to insure a fair market without conflict or interest if 90% of marketable orders of individual investors goes to a small group of six off-exchange dealers. It just can't be guaranteed. A public auction does, it does guarantee transparency. To finish, in order to definitely set examples and trust in the market, the SEC should be able to enforce its rules more than just charging a very relative fine. A market participant breaking any rule should simply be interrupted or get revoked as it didn't comply with the license it has been given. If you want to be in a system, play by the rules or be out. Integrity shouldn't ever be questioned. I wish and want to trust the American stock market. As it is a great opportunity for businesses and individuals to find each other and grow. As long as the rules are enforced and the market is really fair for everybody. Thank you for your attention, Sincerely, Benoît Varela