Subject: File No. S7-31-22; Release No. 34-96495: Order Competition Rule
From: Anonymous
Affiliation:

Mar. 31, 2023



Hello SEC, I have the Following comment on the proposed rule above.

The practice of Payment for Order Flow (PFOF) has been banned in the
UK due to concerns regarding conflict of interest. The US market
should also consider a similar ban. Brokers who do not participate in
PFOF handle orders differently, resulting in a higher quality of
execution. A recent study revealed that Robinhood, which generates
approximately 70% of its revenue from PFOF, does not offer
statistically significant price improvement compared to exchanges.
FINRA's Best Execution guidance is violated, as retail investors who
do not use PFOF receive better prices than those who do. Additionally,
FINRA is currently evaluating the impact of not charging commissions
on member firms' order-routing practices and decisions, and the
results of the investigation should be made public. That is why I
believe this Rule should be implemented.

Thank You