Apr. 01, 2023
To Whom this may concern, As someone who is ex-wallstreet this rule absolutely needs to be passed. I wholeheartedly agree that 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 already been banned in the UK due to conflict-of-interest concerns – and this should absolutely 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. According to a recent study, Robinhood does not provide statistically significant price improvement relative to exchanges, despite PFOF being responsible for around 70% of its revenue. Additionally, retail investors not dealing with PFOF get a better price than those dealing with it, which is in direct violation of 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. TD Ameritrade's order routing decisions don't seem to be motivated by competition despite what they state on their website, and they pay to get the first look at orders, routing them to firms that net themselves billions of dollars in the process. 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. It's time to fix this. Thank you for your time, Luke Petersen