Mar. 31, 2023
March 31, 2023
Dear Ms. Countryman:
As an individual retail investor, I thank you for your effort to create more competition and transparency in the market, and I appreciate the chance to comment on these proposals.
In aggregate, these recommended enhancements constitute one of the most significant changes to U.S. equity market structure since Regulation NMS was implemented in 2005.
Investors should have access to the best priced quotations available in the national market system and such
prices generally should be determined by competitive market forces.
It shouldnt be possible to pay billions of dollars for retail orders for the ability to control everything in that entire market.
Citadel recommended withdrawing this proposal for a number of reasons, including the unprecedented nature of requiring certain market participants to utilize a specific trading protocol.
Sending my orders to a wholesaler to be internalized is a specific trading protocol that Id rather pay commission to be able to avoid. A wholesaler such as Citadel who has been front-running customer orders since 2006 shouldnt have a monopoly on retail order flow.
My only concern is that brokers will start charging outrageous commissions or fees in lieu of PFOF, so Id recommend a cap on the amount of commissions or fees that the brokers are allowed to charge.
I trust the Economic Analysis done by the commission and I look forward to retail saving from $1.12 billion to $2.35 billion on transaction costs. These estimated gains would be generated primarily through increased competition to supply liquidity to marketable orders of individual investors, which in turn would lower transaction costs for individual investors, potentially enhance order execution quality for institutional investors, and improve price discovery.
https://www.finra.org/media/document/11737
https://www.finra.org/rules-guidance/rulebooks/finra-rules/5310
https://www.cfainstitute.org/-/media/documents/article/position-paper/payment-for-order-flow-united-kingdom.ashx#::text=Payment for order flow (PFOF) is the practice of market,order flow by market makers
https://www.finra.org/rules-guidance/guidance/reports/2022-finras-examination-and-risk-monitoring-program/disclosure-routing-information
https://www.sec.gov/rules/final/34-43590.htm#secv
https://www.finra.org/rules-guidance/guidance/reports/2022-finras-examination-and-risk-monitoring-program/disclosure-routing-information
https://www.sec.gov/files/reg-nms-rule-606-disclosures-risk-alert.pdf
https://www.thetradenews.com/citadel-securities-forks-out-2-6-billion-annually-for-payment-for-order-flow-and-most-of-its-on-options/
https://files.brokercheck.finra.org/firm/firm_116797.pdf
https://www.merriam-webster.com/dictionary/monopoly
https://www.sec.gov/rules/proposed/2022/34-96495.pdf
https://www.sec.gov/rules/final/2020/34-90610.pdf
https://press.princeton.edu/ideas/how-to-make-money-in-nanoseconds
https://news.gamestop.com/static-files/5a610aaf-6606-4173-86a1-cba6abdb204a