Subject: Rv: File No. S7-31-22; Release No. 32-96495: Order Competition Rule
From: Aaron Carpi
Affiliation:

Mar. 31, 2023

 




De: Aarón Carpi 
Enviado: viernes, 31 de marzo de 2023 15:03 
Para: 
Asunto: Fwd: File No. S7-31-22; Release No. 32-96495: Order Competition Rule 
  





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De: Aarón Carpi  
Enviado: viernes, 31 de marzo de 2023 13:54 
Para: rule-<rule-comments@sec.gov> 
Asunto: File No. S7-31-22; Release No. 32-96495: Order Competition Rule 


To Whom it May Concern, 


I am an individual investor. I would like to voice my support for this proposed rule, which accomplishes several reforms that will make the markets more free and fair. Market Makers have far too many exemptions to the rules that others play by, which gives them an absurd advantage. If they are allowed to internalize orders, they can manipulate the price, plain and simple. 


In the current system, Market Makers have the ability to internalize orders. This inhibits price discovery, and suppresses the natural growth and decline that can occur as a result of buyer sentiment. Correcting this with a public auction for all securities for all market participants is by far the best solution, and they should not be allowed to have any advantage in the trade of securities. 


This rule also addresses Payment for Order Flow (PFOF). PFOF is honestly a grift on the working class and individual investors by the rich. It creates a pay-to-win scenario that allows large firms with excess reserves of cash to gain a ridiculous advantage. PFOF also comes with a litany of concerns about conflicts of interest. There is a reason it was all but banned in the UK, and the US should join the club. 


There is additionally a disparity that exists in the information that is available to market makers and wholesalers versus what is available to the general public. This is perpetuated by Alternative Trading Systems, which allow wholesale firms to exchange capital and securities without reporting to the “lit” exchanges. This causes a two-tier system, where those who can participate in those systems play by one set of trading rules, while those who participate in the open market play by another. Naturally, this gives an advantage to wholesalers, who also play the market for a profit, and who have regularly posted profits in the billions. And it’s no wonder, when they have a virtual monopoly through their cooperation and nepotism. 


Removing the middlemen and requiring everyone to play by the same set of rules will improve prices across the board, and will bring much-needed transparency to a system that has become deliberately opaque. The Commission should ensure fair competition by reducing monopolistic behavior and removing profiteering middlemen from the market. 


This rule, bringing more transparency to the Alternative Trading Systems, should be implemented as soon as possible. 


The SEC should investigate the conflicts of interest inherent with PFOF and market-making activities. Higher fines MUST be levied against entities found guilty of wrongdoing, as it cannot simply become the cost of doing business. For serial offenders, their ability to engage with the securities exchange should be revoked. 


Thank you for your time. 


Regards, 
-Aaron Carpi 


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