Mar. 31, 2023
To Whom it May Concern, I support the ruling that Citadel cannot be the first to receive orders. Every party needs an opportunity to fill orders promoting a healthy market. Historically, payment for order flow and other privileges granted to market makers have been abused, as seen in UK markets. It should be banned in the US as well due to the inherent conflicts of interest. Not only has payment for order flow (PFOF) been shown not to enhance execution and price improvement, a study revealed that Robinhood deals with PFOF for about 70% of their orders and it has shown no enhancement in execution nor price for retail investors. FINRAs study evaluations of non-charged commission for order routing practices should be publicized as it probably will show it enhances market efficiency and competition. Dark pools (Alternative Trading systems) need greater transparency with quotes and trade volume to enhance the quality of market data. Currently, American markets are anti-competitive functioning gainst the very principles this country was founded on. It is the commission's duty to ensure fair competition with regard to off-exchange systems and privileges granted to wholesalers. As they have abused their influence on market participants, Wholesalers need greater transparency and regulation on their inherent monopolizations on market function and order routing. This has to be done to protect the integrity of American markets via harsher penalties, such as broker privileges revoked for violations and fines that are significantly higher in relation to the amounts of wealth siphoned by illegitimate practices. Respectfully, Brock Fuchs