Mar. 31, 2023
To the SEC, This is my support for the Order Competition Rule. Even though I very much want to see rules being enacted and fines that are worthy of the name (and not just cost of doing business), this rule for me is a step in the right direction. Orders must go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order and not first go to firms like Citadel. I believe that in a fair and open market, there must not be front-running or hidden costs that could otherwise affect my trades. As a houshold investor, Payment for Order Flow (PFOF) is NOT in retail- or houshold-investors interest. It is of great concern to me, that businesses offer seemingly cheap or free execution while the real cost of trading is hidden and influencing orders throught the market. I do not want to get a free execution if I can objectively and competitively choose a trade for my own. This conflict-of-interest and needs to be banned. Brokers who do not accept any kind of PFOF route orders differently and consequently see superior execution quality. In fact, 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, therefore violating FINRA's Best Execution guidance. Any evaluation of the impact of not charging commissions on member firms' order-routing practices and decisions and the findings should be made public. TD Ameritrade's 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. Dark pools (Alternative Trading Systems) should provide quotes and trades to consolidated market data to bring more transparency to dark markets. The SEC 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. Removing 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 SEC 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 instead of receiving fines that amount to a cost of doing business. The market needs to be open, fair and with clear rules that are swiftly, strictly and long lastingly enforced. Household investors like myself can not navigate the multitude of rule exemptions, report delays, only limited and incomplete or even false datasets that are available to simple household investors. Thank you and in hope of change towards equality, JP Bruns