Mar. 26, 2023
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Enforcement is key to the effectiveness of SEC rules. Higher fines are necessary to serve as a real deterrent, and some broker-dealers should lose their licenses instead of being let off with mere fines. I am fully supportive of this rule and urge the SEC to implement it as soon as possible. Any steps to reduce speed games and eliminate the farming of individuals' orders for rebate money are deeply appreciated and necessary to restore the integrity, credibility, and functioning of American markets. The current market structure, where some brokers first route orders to a wholesaler who then passes them to an auction, is overly complicated and gives the wholesaler an unfair advantage by letting them see orders before anyone else. The SEC should require brokers to first route orders to the auction and only to the wholesaler if the auction is unsuccessful, to ensure equal knowledge across the entire market. The recent rule change requiring dark pools to provide quotes and trades to consolidated market data if they wish to operate as an auction is a step in the right direction. The investing public deserves transparency and easy access to information on what is happening within the markets. Fair competition is essential for the protection of investors and the maintenance of fair and orderly markets, but the current state of the American markets is anti-competitive. Monopolies are bad, and the Commission must do more to ensure fair competition, especially within the off-exchange systems that currently dominate. This proposed rule is an important step towards a simpler, more transparent, and free market structure that benefits all market participants. It will help eliminate the conflicts of interest present when orders are routed through wholesalers with a record of flouting the law, like Citadel Securities. Wholesalers exercise extreme influence on other market participants, and this influence must not be allowed to infect the ability of some participants to objectively review these rules. Research indicates that internalization is detrimental to markets. Wholesalers are lying about the quality of their services to maintain their profits, and it is unacceptable that they take billions from individuals and institutions and call it "superior performance". Removing profiteering middlemen from the market will improve prices for both individuals and institutions, including pension funds. Recent research by Hittal Mittesh estimates that removing wholesalers from the market would save individuals billions of dollars and institutions over $1.5 billion each year. Let us stop the profiteering and return the savings to citizens and pension funds.