Subject: S7-31-22: WebForm Comments from Charles S
From: Charles S.
Affiliation: Scientist

Apr. 01, 2023



 April 1, 2023

 As an investor, I am compelled to emphasize the importance of effective enforcement and deterrents when it comes to regulations implemented by the SEC. Adequate fines and sanctions, including the potential loss of licenses for broker-dealers, will ensure that these rules are not merely seen as a cost of doing business but instead act as a powerful deterrent to violations.

I wholeheartedly endorse the proposed rule and urge its swift implementation. I commend any effort to diminish manipulative speed games and practices that compromise the integrity, credibility, and functionality of the U.S. markets.

Furthermore, I applaud initiatives that aim to reduce incentives for 'farming' individuals' orders for rebate money and to streamline the order routing process in a manner that promotes equal knowledge among all market participants.

I support increased transparency in Alternative Trading Systems, as it benefits the investing public by providing them with more accessible information regarding market activity.

Promoting fair competition is crucial to the health of the market, as outlined in section 11A of the 15 U.S.C. 78k-1. Addressing anti-competitive behavior, particularly within off-exchange systems, is essential for the SEC to fulfill its mandate.

Monopolistic practices are detrimental to the market, and it is imperative that the SEC works to create a fair and competitive environment. The proposed rule represents a significant stride towards achieving this goal.

Simplifying and unifying the market structure will benefit all participants, particularly by reducing the undue advantages enjoyed by dominant players. The proposed rule aligns with these objectives.

Regarding wholesalers, it is crucial to address potential conflicts of interest and ensure that consumers have a choice in avoiding them if they so desire. Research indicates that internalization can be harmful to markets, and it is essential to critically examine the role of wholesalers in the current market structure.

Efforts to remove profiteering middlemen and redirect savings towards citizens and pension funds, rather than Wall Street's coffers, should be lauded. Research by Hittal Mittesh supports this notion, highlighting the potential for significant annual savings for both individuals and institutions.

In conclusion, the proposed rule is a critical step towards fostering a more transparent, fair, and competitive market landscape that benefits all participants.

Kind Regards
Charles