Subject: Comment on proposed order competition rule S7-31-22
From: Roth Chance
Affiliation:

Mar. 27, 2023

Hello, 


Thank you for allowing me to comment on the proposed order competition rule. I fully support the efforts of the SEC to limit wholesaler internalization by adopting the proposed auction system. Markets cannot be free nor fair when large swathes of orders are prevented from impacting price discovery through wholesaler internalization. Every single order should have an equal opportunity to affect price, regardless of where it originated or order size.  


Wholesalers do not speak for me, I would gladly give up any price improvement they claim to provide for me to ensure that every single order hits the tape on lit markets. The conglomerate market makers, hedge funds, and clearing houses have decimated household investors' trust in our markets using practices like internalization, abusive naked short selling masquerading as "market maker exemptions", and strategic failures-to-deliver. It is well past time for regulators to address these egregious violations by enforcing rules for all market participants equally, handing down meaningful penalties consubstantial with the full scope of the crime, eliminating rebates and payment for order flow, and eliminating any and all loopholes/exemptions. 


There is a gross imbalance of fairness in our markets today. I hope that with the passage of proposal S7-31-22, some of that fairness can be returned. Thank you for your time. 







Regards, 


Roth Chance