Mar. 31, 2023
Dear SEC, Allow me to introduce myself. I'm Aaron. I'm a 40 year old tax-paying, home-owning, tech-industry-working, family-having household investor. And as I read the proposed Order Competition Rule I feel something I haven't felt in a long time: hope that our markets could get better. Over the last few years, as I've become more invested in my investments (dad joke), I've taken it upon myself to learn as much as I can about our markets and market structure, the major players, their business strategies, and - most importantly - their systematic advantages. It's what any good engineer would do when interacting with a new system; learn it top to bottom. And what I've learned makes me deeply pessimistic about our capital markets, about the course of American capitalism, and about the direction of our country as a whole. Studies have shown - mathematically, and beyond a reasonable doubt - that household investors submitting orders via a PFOF order methods receive worse pricing than those without, violating FINRA's best execution guidance. The advantages taken by wholesalers and market makers to have brokers first route to auction, and only specify where the order should go if the auction is unsuccessful is ridiculous. The Commission should address the systemic information asymmetry present in our markets; for a market to be free and fair, the market must be accessible to all participants. The state of American markets is anti-competitive, and fair competition is essential. Dark Pools (ATS), internalization, and other off-exchange systems need to be strictly regulated to ensure competition in the market exists. If only some orders from some participants are allowed to reach markets, and order routing is decided by companies who have a vested interest in the stock moving in a specific direction, then price manipulation and anticompetitive practices not only become easy, but a logical next step to increase profits. The Commission should not allow these types of conflict of interest to go unchecked. These should be investigated, with penalties that are not just another business expense. The systematic fleecing of the American public is fraud, and broker-dealers caught perpetrating that fraud should lose licenses instead of fines. Please, please do something. Restore our hope. Help us believe the future of American markets is free, fair, and open to all. Thank you for your time, Aaron Kolysko