Subject: File No. S7-31-22; Release No. 34-96495: Order Competition Rule
From: Zaf Khan
Affiliation:

Mar. 24, 2023

Dear Sir/Madam,
 
I support this rule.
 
The current state of American markets is nothing short of unfair and anti-competitive – and it's time to take action. The Commission must ensure fair competition, with a particular focus on the off-exchange systems that are currently dominating. Wholesalers are taking billions from individuals and institutions, claiming it is 'superior performance' whilst delivering the opposite.  This has to stop. 


To combat this, the Commission should implement a new rule which states that Citadel cannot be the first to receive orders; instead, orders must go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order. Payment for Order Flow (PFOF) should be effectively banned in the US, just as it has been in the UK due to conflict-of-interest concerns. 


Furthermore, higher fines should be implemented as a deterrent for breaking the law, and some broker-dealers should have their licenses revoked for profiting from the market. The proposed rule to bring more transparency to dark markets should also be implemented as soon as possible, and FINRA should investigate conflicts of interest among market participants to ensure that everyone is objectively reviewing the rules. 
By taking these steps, individuals and institutions, such as pension funds, would save billions of dollars taken by wholesalers and get a better price without dealing with PFOF. It's time to start bringing fairness and competition back to the US markets. 
 
Thank you for your consideration.
 
ZK.