Subject: Re: Order Competition Rule, File No. S7-31-22, Release No.34-96495
From: Witold Tatkiewicz
Affiliation:

Mar. 31, 2023

 



Dear Reviewer, 


I am in favour of this rule as it returns freedom to financial markets. 
  
Broker orders transmitting should be democratic, market wide and transparent process and not managed in its entirety by wholesaler. 
  
I fully support the rule, please implement it as soon as possible and restore health to markets and playing ground for household investors. 


  
COMPETITION IS GOOD 
  
15 U.S.C. 78k-1 (“section 11A”) states that "It is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure ... fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets." For too long the Commission has not be enduring fair competition, especially within the off-exchange systems that currently dominate. It's good to see they are beginning to take their mandate more seriously.  
  
Monopolies are bad, and there is clear monopolistic behavior here. The Commission notes that 90% of marketable orders of individual investors in NMS stocks to a small group of six off-exchange dealers, and 66% is captured by just two firms. Those figures will be even higher for specific stocks. The state of American markets is clearly anti-competitive and that needs to change.  




I also think institutions' licences should be revoked in case of persistent breach of rules. 


Kind regards, 
WT