Subject: Comments on S7-31-22; Release No. 34-96495: Order Competition Rule
From: Lars Wohlfahrt
Affiliation:

Mar. 23, 2023



Dear Sir or Madame,

I am writing to express my strong support for Rule S7-31-22; Release No.
34-96495: Order Competition Rule. The proposed rule would improve
competition in the securities markets and ultimately benefit investors
by promoting fairer pricing, increased transparency, and greater innovation.

The proposed rule would encourage competition by reducing barriers to
entry and promoting market data transparency. This would enable smaller
firms to compete on a more level playing field with larger incumbents,
driving innovation and providing investors with better access to diverse
products and services.

I believe that increased competition will ultimately result in more
efficient and resilient markets, better risk management, and more choice
for investors. This is particularly important in the current
environment, where technological advancements have made it easier for
new firms to enter the market and challenge established players.

Furthermore, the proposed rule is consistent with the SEC's broader
mission to protect investors and promote fair, orderly, and efficient
markets. By fostering competition, the SEC can help ensure that market
participants are held to the highest standards of conduct and that
investors are protected from abusive practices.

The new rule to mandate a public auction for order placement instead of
giving Citadel priority is important to ensure fair opportunity for all,
including pension funds.

Conflict-of-interest concerns have led to the effective ban of Payment
for Order Flow (PFOF) in the UK, and the US market should follow suit.

Brokers that avoid PFOF exhibit different routing behavior and generally
provide better execution quality.

Despite generating approximately 70% of Robinhood's revenue, a recent
study found that PFOF does not result in statistically significant price
improvement relative to exchanges.

In summary, I fully support Rule S7-31-22; Release No. 34-96495: Order
Competition Rule and urge the SEC to adopt it without delay. The
proposed rule will promote competition and innovation in the securities
markets, ultimately benefiting investors and strengthening the broader
economy.

Thank you for your attention to this important matter.


Sincerely,

Lars Wohlfahrt