Mar. 27, 2023
Hello Ms. Countryman, The proposed regulation aimed at promoting competition and transparency in the NMS stock market is a crucial move towards fairer trading practices. The rule's provision for public auctions that grant all participants an equal chance to fill orders, instead of favoring only Citadel, is particularly admirable. Payment for Order Flow (PFOF) has long been a contentious issue, and the suggested ban on PFOF is a vital step in addressing concerns about conflicts of interest. The study's finding that Robinhood's PFOF contributes to about 70% of its revenue, yet fails to provide significant price improvement, is worrying, further reinforcing the need for a ban on this practice. The proposed rule's focus on ensuring broker routing decisions are guided by competition is a commendable initiative. Brokers who do not accept PFOF should not be disadvantaged and should be able to route orders differently for better execution quality. The impact of not charging commissions on member firms' order-routing decisions should be thoroughly evaluated, and the results made public. The suggested requirement for dark pools to provide quotes and trades to consolidated market data is a much-needed measure to bring more transparency to dark markets. Wholesalers' overwhelming influence on other market participants creates conflicts of interest, which require attention. Removing middlemen from the market will lead to better prices for both individuals and institutions and save billions of dollars currently lost to wholesalers. Overall, the proposed regulation is a positive step towards ensuring fair competition and transparency in the NMS stock market. The SEC needs to investigate conflicts of interest among market participants, ensuring the rules are objectively reviewed, and improve enforcement by imposing higher fines to serve as a significant deterrent for breaking the law. Additionally, the Commission should consider revoking licenses of broker-dealers who repeatedly break the rules, rather than just fining them for a fraction of their revenue and thus reducing the fines to “cost of operating”. Met vriendelijke groet / with kind regards, Eege Klop Oprichter Telefoon: Email: Web: nova-nl.net Linkedin: Nova BV