Mar. 21, 2023
Hello, I am writing to express my support for the proposed rule related to the stock market, which is aimed at promoting fair competition and transparency in the market. I would like to highlight several key talking points regarding this rule that I believe are essential to ensuring a level playing field for all market participants. Firstly, I fully endorse how this rule prohibits Citadel from being the first to receive orders. Instead, orders should go through a public auction where everyone, including pension funds, has an equal opportunity to fill the order. This measure will ensure that all market participants have a fair chance to benefit from the order flow and prevent any undue advantage to specific players. Secondly, Payment for Order Flow (PFOF) has been effectively banned in the UK due to conflict-of-interest concerns, and this should also be the case in US markets. Brokers who do not accept any kind of PFOF route orders differently and consequently see superior order execution quality. The recent study that found Robinhood does not provide statistically significant price improvement relative to exchanges, despite PFOF being responsible for around 70% of its revenue, raises serious concerns. Retail trades not executed using PFOF get a better price than those not, which is in violation of FINRA's best execution guidance. Thirdly, I urge FINRA to evaluate the impact of not charging commissions on member firms' order-routing practices and decisions, and the findings should be made public. Additionally, TD Ameritrade's order routing decisions don't seem to be motivated by competition despite what they state on their website, and they pay to be the first to see orders, routing them to firms that net themselves billions of dollars in the process. Fourthly, I support the proposal to bring more transparency to dark markets by having dark pools (Alternative Trading Systems) provide quotes and trades to consolidated market data. This measure will increase transparency and fairness in the market, allowing market participants to make more informed decisions. Finally, I would like to stress that the state of American markets is anti-competitive, even though fair competition is essential. Wholesalers exercise extreme influence on other market participants, and there are conflicts of interest that may infect the ability of some participants to objectively review the rules. Wholesalers are taking billions from individuals and institutions and calling it "superior performance" while lying about the quality of their services to maintain their profits. Removing middlemen from the market will improve prices for both individuals and institutions, such as pension funds. The auctions would save individuals billions of dollars taken by wholesalers. In conclusion, I strongly support the proposed rule related to the stock market and urge the SEC to implement it as soon as possible. The Commission should ensure fair competition by reducing monopolistic behavior and removing profiteering middlemen from the market. The SEC should investigate conflicts of interest among market participants to ensure that participants can objectively review the rules, and the enforcement of SEC rules needs to be improved with significantly higher fines and time in prison to serve as a significant deterrent for breaking the law. Some broker-dealers should lose their licenses instead of receiving fines that amount to "the cost of doing business". Thank you for your time and consideration.