Subject: File No. S7-31-22; Release No. 34-96495: Order Competition Rule
From: Dominic Apicella
Affiliation:

Mar. 31, 2023

 


To Whom it May Concern, 


Frankly, that should be everybody working for this agency so hopefully somebody takes note and realizes how incredibly disastrous the lack of enforcement and accountability has been for this country. I would like to start by saying how disappointing it is that every loophole and regulation made during every single period of market and economic stress has hurt not only household investors but every other single person that isn't one of the top financial or government players. Everything being done is in the interest of politicians, market makers, hedge funds, and banks etc. It is a disgusting abuse of power and verges on financial terrorism. 


Now onto the proposal: 


In the current system, pension funds get the short end of the stick. Having a public auction for orders allows for equal opportunity. I'm not entirely sure how this even became an issue in the first place. Who in their right mind would think that preferential treatment in the stock market would benefit anyone worth benefitting?  


Payment for order flow should 100% be banned as well. This conflict of interest is at the same level if not worse than congressional stock trading (which is another issue you turn a blind eye to).  
There is no reason that anyone should be able to profit off our trades because they actively work against us to make those profits. Brokers who don't accept PFOF see superior execution quality and that is what the market should strive for. PFOF brokers sustain themselves through this practice meaning they are working for themselves and not the investors while showing next to no price improvement. It's a bogus defense for supporting PFOF and violates FINRA's Best Execution guidance. 


The American markets are toted "Free and Fair" but as we have seen in the last few years specifically, they are the complete opposite. There is no transparency and wholesalers have an unfair information advantage. This leads to them essentially stealing from the small guys to line their own pockets while coming up with more ways to scam the system in their favor. In any other industry these companies would be broken up under antitrust laws, but in the US stock exchange they are revered because they give investors the best opportunities in the world, This is a blatant lie. They make the markets anti-competitive and have far too much influence on the overall economic health.  


We are seeing the consequences of their greed right now. Banks are failing, the market is tanking, inflation is soaring, and it hurts everyone but the people running the show. If they make a bad bet, the game stops so they don't lose everything. That is not an even playing field. A blind eye cannot be turned any longer. Existing rules need to be enforced and new rules that limit this seemingly unlimited power need to be implemented. The petty fines that are the cost of doing business are not penalty enough. Things will continue to get worse for as long as nothing changes and at some point, this can won't be able to be kicked further. Don't let it get to that point.  


Please listen to everyone telling you this. Stop making rules for these criminals and help the average person. There are far more of them who are much better people who deserve the help you can provide. 


Dom Apicella