Apr. 01, 2023
Aloha, I would like to thank you for your time in this matter. I am a 40 year old new parent that would like to see some change in the market for the future generations. I am in full support of the rule, please implement it ASAP! I have listed below points of interest: Enforcement of SEC rules needs to be improved with higher fines to serve as a significant deterrent for breaking the law. Some broker-dealers should lose their licenses instead of receiving fines. I am 100% in support of the new rule that states that Citadel cannot be the first to receive orders; instead, orders must go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order. Payment for Order Flow (PFOF) has been effectively banned in the UK due to conflict-of-interest concerns – please let this be the case in US markets too. Brokers who do not accept any kind of PFOF route orders differently and consequently see superior execution quality. Retail investors not dealing with PFOF get a better price than those dealing with it, violating FINRA's Best Execution guidance. FINRA is evaluating the impact of not charging commissions on member firms' order-routing practices and decisions, and the findings should be made public. Dark pools (Alternative Trading Systems) should provide quotes and trades to consolidated market data to bring more transparency to dark markets. The Commission should address the unfair information advantage of wholesalers by having brokers first route to the auction and specify where the order should go if the auction is unsuccessful. The state of American markets is anti-competitive, and fair competition is essential. The Commission needs to ensure fair competition, especially within the off-exchange systems that currently dominate. Wholesalers exercise extreme influence on other market participants, and there are conflicts of interest that may infect the ability of some participants to objectively review the rules. Removing middlemen from the market will improve prices for both individuals and institutions, such as pension funds. The auctions would save individuals billions of dollars taken by wholesalers. The Commission should ensure fair competition by reducing monopolistic behaviour and removing profiteering middlemen from the market. The proposed rule to bring more transparency to dark markets should be implemented as soon as possible. Respectfully, KEITH NOBLE