Mar. 27, 2023
March 27, 2023 Dear SEC, As a concerned market participant and Household Investor, I would like to address the primary problems in our current market structure. One of the main issues is the fragmentation of liquidity across various market centers, which can lead to increased trading costs and reduced price discovery. Additionally, there is a lack of transparency in the market, with some market participants having access to order book information that is not available to others. I believe that a Trade-At rule is the preferred solution to these problems. A Trade-At rule would require orders to be executed within the national best bid and offer (NBBO) when they are submitted to a market center, promoting price discovery and improving transparency. By reducing the fragmentation of liquidity and creating a more level playing field for all market participants, a Trade-At rule would also increase competition and innovation. However, if the Commission does not adopt a Trade-At rule and proceeds with the OCR Proposal as constructed, I believe that there are important changes that should be made to reduce unintended consequences and allow for the most competitive and innovative trading environment. These changes include the requirement for market centers to provide real-time public display of their order books, as well as fair and reasonable access to their order books. Additionally, market centers should be required to have procedures in place to prevent discrimination against any person or category of persons in the provision of access to their order books. Overall, I believe that a Trade-At rule would be the most effective solution to the problems in our current market structure. However, if the Commission decides not to adopt a Trade-At rule, I urge the Commission to carefully consider the changes outlined above to ensure that the OCR Proposal promotes competition, innovation, and a fair and transparent market environment for all market participants. Thank you for your consideration. Sincerely, Robert Graham Brunner