Mar. 31, 2023
March 31, 2023 Access to the best-priced quotations available in the national market system should be a right for all investors, and these prices should be determined by competitive market forces. Allowing certain market participants to control the entire market by paying billions of dollars for retail orders is not acceptable. Citadel has recommended withdrawing a proposal that would require certain market participants to utilize a specific trading protocol due to the unprecedented nature of such a requirement. However, I believe that sending my orders to a wholesaler such as Citadel to be internalized is a specific trading protocol that I would rather pay a commission to avoid. Wholesalers like Citadel, who have been front-running customer orders since 2006, should not have a monopoly on retail order flow. I do have concerns that brokers may start charging outrageous commissions or fees in lieu of PFOF, so I recommend implementing a cap on the amount of commissions or fees that brokers are allowed to charge. I trust the Economic Analysis conducted by the Commission and I am optimistic about the estimated savings of $1.12 billion to $2.35 billion in transaction costs for retail investors. These savings would primarily result from increased competition to supply liquidity to marketable orders of individual investors, which would lower transaction costs and potentially enhance order execution quality for institutional investors, as well as improve price discovery.