Mar. 23, 2023
Ms. Countryman: We The Investors (“WTI”) appreciate the opportunity to comment on the U.S. Securities and Exchange Commission’s (the “SEC” or “Commission”) Order Competition Rule Proposal (the “OCR Proposal”). We The Investors are organized around five key principles as laid out in our Investors’ Bill of Rights. These include Transparency; Simplicity and Fairness; Choice and Control; Best Execution; and Better Settlement and Clearing. This comment letter will focus on three of those principles: Transparency; Simplicity and Fairness; and Best Execution. 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. It is clear to me that excessive shifts of trading volume to off-exchange has the efect of stunting price discovery. Siphoning off all of those orders into wholesalers means that many orders do not hit the NBBO which hinders supply/demand and company values aren't reflective of investor activity and interest It is also clear to me that the purposeful triggering of SSR is routinely abused in order to create huge amouts of short exempts. How can it be fair if excessive synthetic selling volume can be routinely produced at time of execution but any punsishments for failing to deliver are served far too long after the damage to companies have been done. Sincerely Mr John hannaford / Programmer