Mar. 26, 2023
To whom it may concern, S7-31-22 is important to improve the current anti-competitive state of American markets. The Commission needs to ensure fair competition, especially within the off-exchange systems that currently dominate. Increased transparency and competition in the National Market System (NMS) for stocks is an important step in the right direction towards fairer markets. The rule's support for public auctions that give all participants an equal opportunity to fill orders, rather than just giving the first right to Citadel, is especially commendable. Payment for Order Flow (PFOF) has long been a controversial issue, and the proposed ban on PFOF is a necessary measure to address conflicts of interest concerns. Ensuring that broker routing decisions are motivated by competition is a welcome move. Brokers who do not accept any kind of PFOF should not be at a disadvantage, and should be able to route orders differently and see superior execution quality. The need to evaluate the impact of not charging commissions on member firms' order-routing practices and decisions is an important consideration, and the findings of this evaluation should be made public. Bringing more transparency to dark markets by requiring dark pools to provide quotes and trades to consolidated market data is also a much-needed measure. Wholesalers exercise extreme influence on other market participants, and the conflicts of interest that arise from their profiteering need to be addressed. Removing middlemen from the market will improve prices for both individuals and institutions, and save billions of dollars taken by wholesalers. S7-31-22 is a positive step towards ensuring fair competition and transparency in the market for NMS stocks. The SEC should investigate conflicts of interest among market participants to ensure that the rules are objectively reviewed. Further, enforcement of SEC rules needs to be improved with SIGNIFICANTLY higher fines to serve as a deterrent for breaking the law. Fines are currently a “cost of doing business” and thus currently have no effect on the behavior of market participants. The Commission should also revoke licenses of broker-dealers who repeatedly break the law, rather than just fining them. Then, and only then will market participants start to take the rules and laws seriously. Thank you for your time, Tristan Henderson