Mar. 31, 2023
To whom it may concern, I am writing to express my strong support for File No. S7-31-22; Release No. 34-96495: Order Competition Rule. It is my belief that this new rule is an essential step towards fair competition within the American markets. It is vital that all market participants, including pension funds, have an equal opportunity to fill orders rather than orders automatically going to Citadel. The new rule would require orders to go to a public auction, which will ensure that all market participants have a fair and equal opportunity to fill the order. In the UK, Payment for Order Flow (PFOF) has been banned due to conflict-of-interest concerns, and I believe the same should apply in US markets. Brokers who do not accept any kind of PFOF route orders differently and, consequently, see superior execution quality. 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. 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. Dark pools (Alternative Trading Systems) should provide quotes and trades to consolidated market data to bring more transparency to dark markets. 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. I urge the Commission to ensure fair competition by reducing monopolistic behavior and removing profiteering middlemen. 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. I appreciate your attention to these matters, and I strongly support this new rule. Please let me know if you have any questions or require any further information. Sincerely, Zach Woodward, a concerned investor