Subject: S7-31-22: WebForm Comments from William Bloxham
From: William Bloxham
Affiliation:

Mar. 22, 2023



 March 22, 2023

 I support this proposal. Payment for order flow is currently being used by market makers to front run household investor trades and prevents true price discovery by allowing market makers to chose whether they internalize trades or not. Often, this allows them to bet against the very trades they are supposed to be providing best execution. Orders should be sent to lit exchanges and public auctions to ensure price discovery is actually occurring.

As it stands, this proposal is a significant step in the right direction, however it is important for fair auctions to be primary and for market makers to have the same information as everyone else. Allowing orders to be routed to market makers first provides them an extra information advantage for determining what orders to take. All orders should be routed to auctions first, and only then should everyone be allowed to bid.

Thank you for your consideration.