Mar. 22, 2023
Internalization is one of the greatest threats to price discovery in financial markets.” - Kenneth Griffin Ms. Countryman, I am writing to express my full support for the S7-31-22 Order Competition Rule. Competition is the cornerstone of a healthy and efficient market. It promotes innovation, drives down costs, and ultimately benefits consumers. 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. Open competition for order flow, as well as 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. In many situations, U.S. markets are held up as an example to be avoided by other countries due to the astonishing level of share price manipulation ongoing in our market. This is especially true regarding the level of off-exchange trading and intermediation in U.S. markets. Moreover, this rule will help to prevent market manipulation and fraudulent activity. It will establish clear guidelines for trading practices, and provide regulators with the tools they need to enforce these guidelines. S7-31-22 Order Competition Rule is a necessary step towards creating a more fair and efficient market. I urge you to support this rule and do everything in your power to ensure its swift implementation. Thank you for your time.