Mar. 31, 2023
I am writing to express my strong support for the proposed SEC rule to address anti-competitive practices in American markets. As you know, every rule the SEC passes is only as good as the enforcement that backs it, and I believe that higher fines that serve as a significant deterrent are necessary to ensure compliance. I am particularly concerned about broker-dealers receiving fines that amount to nothing more than a cost of doing business. Instead, some broker-dealers should lose their licenses to ensure that ill-gotten gains obtained through "honest mistakes" are not outweighed by the cost of fines. I deeply appreciate and support any efforts to reduce the speed games that damage the integrity, credibility, and functioning of American markets. I also support efforts to reduce inducements and to reduce the "farming" of individuals' orders for rebate money. In this regard, I believe that the Commission should address the unfair information advantage that wholesalers have over other market participants by having brokers first route to the auction and specify where the order should go if the auction is unsuccessful. Competition is essential for the protection of investors and the maintenance of fair and orderly markets. I am pleased to see that the Commission is taking its mandate more seriously and implementing rule changes that bring more transparency to dark markets. Monopolies are bad, and there is clear monopolistic behavior in the off-exchange systems that currently dominate American markets. The proposed rule is an important step in the right direction to ensure fair competition. I am particularly concerned about the dominance of wholesalers in the marketplace. I would gladly pay more per share to avoid being routed through a wholesaler with a long record of flouting the law like Citadel Securities. The conflicts of interest between wholesalers and other market participants are clear, and research suggests that internalization is bad for markets. Removing profiteering middlemen from the market will improve prices for both individuals and institutions, such as pension funds. Recent research by Hittal Mittesh suggests that the auctions proposed in the rule would save individuals billions of dollars taken by wholesalers and save institutions over $1.5 billion each year. In summary, I strongly support the proposed SEC rule to address anti-competitive practices in American markets. Thank you for considering my views on this important matter. Sincerely, Andrew Buck