Mar. 31, 2023
Dear SEC, As a household investor, I strongly support the new rule that would require orders to go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order. This will create a fairer and more transparent market. Furthermore, I believe that Payment for Order Flow (PFOF) should be banned in US markets just as it has been in the UK due to conflict-of-interest concerns. Brokers who do not accept any kind of PFOF have demonstrated superior execution quality. Studies have shown that retail investors not dealing with PFOF get a better price than those dealing with it, violating FINRA's Best Execution guidance. 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. 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. Wholesalers are taking billions from individuals and institutions and calling it "superior performance" while lying about the quality of their services to maintain their profits. Removing middlemen from the market will improve prices for both individuals and institutions, such as pension funds. It is essential for the Commission to ensure fair competition, especially within the off-exchange systems that currently dominate. The proposed rule to bring more transparency to dark markets should be implemented as soon as possible. Furthermore, the SEC should investigate conflicts of interest among market participants to ensure that participants can objectively review the rules. 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 that amount to a cost of doing business. In conclusion, the Commission should ensure fair competition by reducing monopolistic behavior and removing profiteering middlemen from the market. Thank you for considering my views on this matter. Sincerely, Anand Misra