Mar. 29, 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. Vanessa Countryman, Secretary, U.S. Securities and Exchange Commission, 100 F Street, N.E, Washington, D.C. 20549 File No. S7-31-22; Release No. 34-96495: Order Competition Rule Dear Ms. Countryman: The proposed rule to increase transparency and competition in the market for NMS stocks is an important step in the right direction towards fairer markets. The rule's support for public auctions that give all participants an equal opportunity to fill orders, rather than just giving the first right to Citadel, is especially commendable. Payment for Order Flow (PFOF) has long been a controversial issue, and the proposed ban on PFOF is a necessary measure to address conflicts of interest concerns. Furthermore, rules are only as good insofar as they are enforced. I think some broker-dealer's should lose their licenses for repeated violations, instead of simply receiving "fines" that they factor into the cost of doing business. The proposed rule's focus on ensuring that broker routing decisions are motivated by competition is a welcome move. Brokers who do not accept any kind of PFOF should not be at a disadvantage, and should be able to route orders differently and see superior execution quality. The need to evaluate the impact of not charging commissions on member firms' order-routing practices and decisions is an important consideration, and the findings of this evaluation should be made public. The proposal to bring more transparency to dark markets by requiring dark pools to provide quotes and trades to consolidated market data is also a much-needed measure. Wholesalers exercise extreme influence on other market participants, and the conflicts of interest that arise from their profiteering need to be addressed. Removing middlemen from the market will improve prices for both individuals and institutions, and save billions of dollars taken by wholesalers. Overall, the proposed rule is a positive step towards ensuring fair competition and transparency in the market for NMS stocks. The SEC should investigate conflicts of interest among market participants to ensure that the rules are objectively reviewed, and enforcement of SEC rules needs to be improved with higher fines to serve as a significant deterrent for breaking the law. I fully support the approval of this rule. It is good to see the SEC prioritizing true competition in our markets, which is a long-held American value. Thank you for your time and your efforts, and thank you to the SEC for having the courage to challenge the status quo. Sincerely yours, Gina Palazzo