Subject: RE: File No. S7-31-22; Release No. 34-96495: Order Competition Rule
From: John Curtis
Affiliation:

Mar. 21, 2023

 



Vanessa Countryman, Secretary, U.S. Securities and Exchange Commission, 100 F Street, N.E, Washington, D.C. 20549 


File No. S7-31-22; Release No. 34-96495: Order Competition Rule 


Dear Ms. Countryman: 


First off, thank you for your time, and I'm sure your job can't be easy. I'm not a financial wizard or a person with a large stake in the markets, but I do have an opinion based on how I view the America that is often romanticized in our history books. From everything that I have read the past two years to familiarize myself with the topics at hand, the real American market is far from what generations past aspired to build. America is supposed to be home of freedom and fair competition, where a person can make a name for themselves just by being smart or solving a problem in a way no one had thought of yet. And while theoretically this is true, the deck is stacked against anyone who threatens the status quo. For this reason, I support the new rule that states that Citadel cannot be the first to receive orders. Giving everyone an equal opportunity to fill the order in a public auction instead will lead to a more balanced system.  


In addition, Payment for Order Flow (PFOF) has been banned in the UK due to conflict-of-interest concerns, and I see no reason the US shouldn't take a similar approach. Retail investors who aren't using PFOF get a better price than those that do, violating FINRA's Best Execution guidance.  From what I've read, FINRA is evaluating the impact of not charging commissions on member firms' order-routing practices and decisions, and I feel those findings should be made public. You may be surprised by how insightful crowdsourcing can be if you apply a group of dedicated individuals to solving your most complicated issues. We are in an information age, instead of shutting the little guys out, use them to bounce ideas off of. A room of, what 20-50 experts?, versus a chat room of thousands of fans? Between us we can find good solutions that aren't influenced by any entity looking to gain a monopoly.  


Before I get farther off topic, a few additional items: 
- dark pools need to start being required to bring quotes and trades to consolidated market data to make them more transparent. Please do this asap. 
- middlemen are terrible for any industry and only add costs to both sides.  
- please enforce these rules and increase the fines involved to be better proportioned for the profit these criminals gain. If fines can't consistently deter the abuse of the market, licenses need to be revoked. 


And reiterating: Please support the free market and an open auction by supporting this new rule. Remove Citadel as a prioritized order recipient. 




Thank you, and good luck. 
A concerned citizen