Subject: []S7-31-22: WebForm Comments from Benjamin Kirk
From: Benjamin Kirk
Affiliation:

Mar. 31, 2023



 March 31, 2023

 I believe that implementing these rule would create fairer and more transparent markets by allowing for more competition for pricing of trades by first having them hit a public auction. This would also take a large amount of influence and data from the hands of the largest market maker. Seeing that Payment for Order Flow is effectively ban in UK markets it should be the same here in the US markets due to the extreme conflict of interests it creates.
It seems that brokers are not even providing  price improvement through PFOF despite being a very significant part of their revenue. Even further Household Investers are getting better pricing through avenues that do not use PFOF which is a violation of FINRA Best Execution guidance.
The SEC needs to address the unbalanced amount of influence and information advantages that wholesalers have by first having orders hit an auction and regulations as to where the order goes next if auction is unsuccessful. These wholesalers are stealing billions from individuals while falsely claiming the quality of their services.
The level and severity of enforcement of SEC rules needs improvement with much higher fines and punishment to create real deterrents for breaking the law, not just a \"cost of business\" fine.Failure to adhere to rules should lead to loss of licenses.

I fully support this new rule as it will bring fairer markets to the investors in the US.

Thank you for your time in reading my comments and taking them into consideration.