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

Mar. 30, 2023

 


First off, and I'm sure many others have already said this, this simple fact that you waste so much time effort and energy to simply charge a .25% fee of the total amount GAINED by the same institutions you watch over is simply gross negligence and I have lost all hope for a future that has a "fair market" involving any of the current regulatory bodies involved. It's time for action, and it's about time you actually do something that makes a change. 


As someone who currently holds licenses and continues to learn more about the markets - the vast difference regarding the ruleset that institutions have when compared to household investors is out of control and must be stopped. The fact that these institutions can pay for the order flow, internalize the order through SDP's, process through institutionally owned dark pools, trade with their friends, process orders off-exchange equating to typically over 50% and upwards of 85%, and then at the same time front run, run a family- office, and be a market-making-hedgefund-primebroker-individual-unsophisticated-sophisticated investor, all while failing to deliver ungodly amounts of securities under lackadaisical rules that allow exemptions around exchanges basic framework by stating they're "bona-fide" market making is criminal. 


What you're proposing with this bill in regards to forcing orders to go to a public exchange is a wonderful step in the right direction to actually regenerating accurate price discovery and regaining trust in the market from an entire generation the regulatory body has destroyed by simply talking big but wont back anything up.  The duration of auctions would be between 100 milliseconds and 300 milliseconds - This also needs to be removed as a window and set at a standard precise time equivocal to the wired IEX exchange order limitations. I believe that you are allowing HFT traders, which just so happens to be the same market-making-hedgefund-primebroker-individual-unsophisticated-sophisticated investors, to continue to process transactions at a speed faster than most household investors will be able to. Stop allowing these institutions cheat codes to the current market structure.  The minimum pricing increment would be no less than $0.001 for segmented orders and auction responses with prices of $1.00 or more per share - if fractional shares are not considered to be real - then fractional dollars need to stop. This allows the HFT firms to become the market makers, if they already aren't.   


 No fee could be charged for submission of a segmented order. Any permissible fees and rebates would be capped at $0.0005 per share for segmented orders and auction responses with prices of $1.00 or more per share; and Execution priority requirements would, among other things, prohibit giving priority to the fastest auction response or to the auction response submitted by the broker dealer that routed the segmented order to the auction 


For this, remove PFOF and watch your market return to an actual oiled machine instead of this criminally taped together mess that you have created.  


Stop catering to the 1%, the 99% are finally watching.