Mar. 31, 2023
Vanessa Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington DC 20549 Ms. Countryman: I am enthusiastically in favor of adopting this proposal. In the aim of achieving free, open, and fair markets - bringing order fulfillment to a public auction system is such an obvious method of achieving those objectives one is left to wonder how our markets manage to achieve those ideals at present while doing without. Frankly I don't wonder about this as I am convinced that our market system is neither free, open, nor fair at present. This is due to the myriad ways that transactions are conducted away from public scrutiny, both in terms of execution and reporting. For example the current practices of payment for order flow removes transactions away from the public exchanges and redirects them to wholesalers, internalizers, etc, who conduct the transaction via the so called dark pools. When these orders are prevented from reaching the open marketplace the information that those orders convey is prevented from reaching the public, and becomes the sole purview of those who paid for the privilege of receiving those orders. Those who pay for this privileged information then use it to their advantage against the market at large, to the detriment of all other participants, and the health of the nation's market. The only way to achieve the goals of having free, open, and fair markets is to ensure that there is as much information available as possible, to as many people as possible, and as quickly as is practicable. The proposed auction system, which requires bidding to occur in public, is a crucial step towards living up to the ideals that would truly make our market the envy of the world. Thank you for your consideration. -janson