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

Mar. 31, 2023

 


Dear Civil Servant, 


As a retail investor, I appreciate your efforts to promote greater competition and transparency in the market, and I am pleased to provide feedback on the proposed changes. These enhancements to the market structure are significant, and I hope they will be effective and true to their spirit. 


I believe that everyone, regardless of their status or size, should have access to the best-priced quotations available in the market system that supports them. The best market is one with the most effective price discovery that reflects supply and demand, and these prices should generally be determined by healthy competitive market forces. It is not justifiable for anyone to pay for the ability to control orders and then arrange them favorably for their benefit. This is akin to scalping, where individuals pay billions of dollars to profit from the retail orders that I and others place by not going to the lit market of accurate price discovery. 

Citadel's opposition to this proposal is because they stand to lose this scalping technique. Their behavior with Authorized Participants of ETF shenanigans is also concerning. If I lose money the more I trade, the incentive to no-commission trading makes PFOF lucrative. The more information they have on future price discovery, the more profitable they can be before updating price discovery. Given their consistent abuse of trust with record high crimes and fines, Citadel cannot be trusted. They have been front-running customer orders since 2006 and should not have access to a majority (50%+) of retail order flow. 

If these sophisticated trading practices are costly to maintain and justify large fees for handling trades, it's time to invest in making markets more equally accessible, rather than paying billions for a competitive edge in trading speed between Wall Street players. IEX is a great exchange to set profitable standards for retail. The economic analysis conducted by the commission indicates that retail investors could save between $1.12 billion and $2.35 billion on transaction costs, which is a significant step forward. Through increased open competition to supply liquidity to marketable orders of individual investors, these savings could translate to lower transaction costs for individual investors, potentially enhancing order execution quality for institutional investors, and improving price discovery. 

Thank you for your attention to these matters. 

Sincerely, 
An individual retail investor