Mar. 31, 2023
Hello SEC, As a concerned and interested stockholder, shareholder, and investor in the United States equity markets, I want my support for this rule to be recorded. I support this rule because aany particular market maker should not be the first to receive orders; instead, orders should go to a public auction where everyone has an equal opportunity to fill the order. Payment for Order Flow (PFOF) has been effectively banned in the UK and many other markets around the world due to conflict-of-interest concerns – and this should absolutely be the case in US markets too. It is an established fact that Brokers who do not accept any kind of PFOF route orders differently and consequently see superior execution quality, this is in the United States interest. A recent study found that Robinhood does not provide statistically significant price improvement relative to exchanges, despite PFOF being responsible for around 70% of its revenue. Retail investors not dealing with PFOF get a better price than those dealing with it, violating FINRA's Best Execution guidance. I expect this rule to address this violation. Major retail brokerages, such as TD Ameritrade, order routing decisions don't seem to be motivated by competition despite what they state on their website, and they pay to get the first look at orders, routing them to firms that net themselves billions of dollars in the process, which is a direct theft of value from their clients. Dark pools (Alternative Trading Systems) should provide quotes and trades to consolidated market data to bring more transparency to dark markets. The Commission should address the unfair information advantage of wholesalers by having brokers first route to the auction and specify where the order should go if the auction is unsuccessful. The state of American markets is anti-competitive, and fair competition is essential. The Commission needs to ensure fair competition, especially within the off-exchange systems that currently dominate. Wholesalers exercise extreme influence on other market participants, and there are conflicts of interest that may infect the ability of some participants to objectively review the rules. Wholesalers are taking billions from individuals and institutions and calling it "superior performance" while lying about the quality of their services to maintain their profits. This rule helping to remove middlemen from the market will improve prices for both individuals and institutions, such as pension funds. The auctions would save individuals billions of dollars taken by wholesalers. The Commission should ensure fair competition by reducing monopolistic behaviour and removing profiteering middlemen from the market. The proposed rule to bring more transparency to dark markets should be implemented as soon as possible. The SEC should investigate conflicts of interest among market participants to ensure that participants can objectively review the rules. Enforcement of SEC rules needs to be improved with higher fines to serve as a significant deterrent for breaking the law. Broker-dealers should lose their licenses for violations instead of receiving fines that amount to a cost of doing business. With urgency and high expectations, Christopher McBride