Subject: Comment Letter for File Number S7-31-22 Order Competition Rule
From: Scott MacDonald
Affiliation:

Mar. 29, 2023

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"In the long run, unfettered internalization will result in substantially poor executions for all retail and institutional investors." 
-Ken Griffin, CEO Citadel, from 2004 


Now he uses precisely this internalization to rig orders in his favor. PFOF is a cancer that is eroding our markets and making them increasingly unfair and uncompetitive. There's a reason the practice is banned in many countries around the world. The SEC proposed rule is in the right spirit but does not go far enough and the porposed auction format is just bandaid that will eventually be abused by criminals like Ken Griffin. This can be summed up very simply without jargon or complicated charts and graphs, the very basis of our capitalist system is predicated upon supply and demand, I have something you want and its rare (i.e. not many sellers) then it costs more to get me to sell it to you. On the flipside if its something that is common and which everyone is selling then its going to cost less and the price should reflect that. You cannot have open and fair markets when you allow market makers to internalize one side of the equation while letting the other go to the lit market, it is market manipulation plain and simple. With almost no exceptions, I believe that all trades should be going to the lit market and the basic principals of supply and demand controling the price, not criminal internalizers and their algorithms. I urge you to do the right thing and support open and fair markets for all. 



Andrew O'Neil