Mar. 22, 2023
I support what “we the investors” is proposing, I took a couple of snippets below from the proposal that speaks to me. Markets function best when there is open, transparent and fair competition for order flow. In all rulemaking efforts, regulators should ask themselves how the rule in question furthers these goals. It is clear beyond a reasonable doubt that our current market structure is anything but open, transparent and fair. The Commission has authoritatively substantiated our concerns, and those of Citadel CEO Ken Griffin, who expressed his own unease over market structure in a strongly worded 2004 comment letter to the SEC. Speaking specifically about U.S. equity markets and the proposed Regulation NMS, Griffin explained that “[i]n the long run, unfettered internalization will result in substantially poor executions for all retail and institutional investors.” I could not agree more. The fundamental flaws in our market structure are plain to see. Today, therefore, one important question remains–what can be done to remedy the situation? The OCR Proposal is one idea. WTI believes that it represents an improvement over our current market structure, and we fully support it. However, we do not believe that the OCR Proposal is the optimal regulatory response to the problems in our markets. We support open competition for order flow, and also believe that innovation and competition are healthy forces for finding optimal economic outcomes. The ideal place for such competition to occur is at the NBBO. That is where the broadest and most diverse set of participants can come together. If exchanges want to offer qualified auction facilities, they should be permitted to do so, but there should be more room for innovation than what the Commission has advanced in the OCR Proposal. Thank you, Martin Rudzki