Subject: File No. S7-31-22; Release No. 34-96495: Order Competition Rule
From: Brandon Seifker
Affiliation:

Mar. 30, 2023

 


The proposed rule to improve competition for executing orders from individual investors is a step in the right direction for a truly free market that is built for all shades of investors. Currently, retail brokers send more than 90% of these orders to a small group of off-exchange dealers who execute them without providing opportunities for other market participants making the market noncompetitve for a large swath of the population. 


As stated, while this practice reduces costs for liquidity providers, the SEC's analysis shows that wholesalers do not fully reflect the much lower cost in the price improvement offered. The competitive shortfall is a cash cow for vested interests at the expense of the party making the trade in some cases, turning our capital forming markets from an instrument of wealth building and rewarding innovation to one that can be cornered and gamed by unfairly privilledged players.  


When trades meet fair and open auctions before they can be executed internally we will start to see a market that accurately reflects sentiment of investors and capital flow rather than one of fulfilling predetermined outcome by some of Wall Street's most powerful. 



The proposed rule would also benefit investors generally, including institutional investors, by giving them direct access to individual investor orders that are mostly inaccessible to them under the current market structure. This is a big win for common Americans who invest their money with third party funds under the impression that this simple market structure is already the case. 

To end, the proposed rule is a positive step towards promoting competition and transparency in the market structure. It would benefit individual investors by providing them with opportunities to receive more favorable prices for their orders and benefit investors generally by promoting competition and transparency in the market. 


I applaud the SEC for their thoughtful consideration in the rules change and commitment to unraveling the complexity with the limitted resources they have at hand, to promote strong foundational policies for our market.