Mar. 22, 2023
By Email Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 205499–1090 rule-comments@sec.gov Dear Ms Countryman - Thank you for reading this comment. I'll try to be brief. This is strong evidence to support that the competitive shortfall savings in the OCR Proposal significantly and materially understates the likely benefit to individual investors, as it is only a measure of the competitive shortfall and benefits in the current market. A market in which overall adverse selection is materially lowered on-exchange will result in a significant tightening of quoted spreads, which will provide benefits above and beyond the current competitive shortfall. (Please refer to the several 'We The Investors' comments you are receiving, showing direct evidence for this.The reduction in adverse selection on-exchange will increase the profits to on-exchange market makers, which will result in increased on-exchange competition, tighter spreads and deeper, more liquid markets. Fairer, deeper, more liquid markets of my advocacy that Trade-At rules, based on the Canadian model, be adopted for US markets. Best regards, Jefferson Rich Individual Investor and Concerned Citizen