Subject: S7-31-22: WebForm Comments from Matt Simonelli
From: Matt Simonelli
Affiliation:

Mar. 26, 2023

March 26, 2023

 Rule Proposal No. 34-96495 File No. S7-31-22 Order Competition Rule

Dear SEC,

I am writing in support of Rule Proposal No. 34-96495 File No. S7-31-22 Order Competition Rule. Markets operate best when transparent and fair competition for order flow exists. Internalization of orders threatens true price discovery in financial markets and results in poor executions for individual investors. On-exchange liquidity will provide healthier competition for the betterment of all participants.

Orders should first be routed to auction before being received by wholesalers to improve prices for individuals and institutions such as pension funds. Currently, there are no guarantees that broker-dealers executing trades to wholesalers like Citadel first are without a conflict of interest. The proposed ban on PFOF is necessary to address these conflicts of interest concerns. Furthermore, I would like additional enforcement and harsher fines/penalties for those abusing these rules.

This order competition rule to improve transparency should be implemented as soon as possible to increase investors' trust in the market.

As an individual investor, I prefer a more straightforward, transparent, and free market structure like the one proposed in this rule.

Thank you for your time.

Sincerely,
Matt Simonelli