Mar. 31, 2023
I strongly support this rule and hope that it is implemented as quickly as possible. 15 U.S.C. 78k-1 (“section 11A”) states that "It is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure ... fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets." Competition is necessary in our markets, and with 90% of marketable orders of individual investors in NMS stocks going to a small group of six off-exchange dealers (and 66% captured by merely two firms), American markets are currently extremely anti-competitive. The current state of the market is dominated by monopolistic behavior and an unfair playing field, and this proposed rule is a vital step in remedying this. Wholesalers like Citadel Securities are untrustworthy and have a long history of disregarding the law and only receiving slap on the wrist, "cost of business" fines. Brokers who do not accept Payment for Order Flow (PFOF) route orders differently and therefore experience vastly better execution quality. PFOF has effectively been banned due to conflict of interest concerns in the UK, and it would be in the American market's best interest to do so as well. As an individual investor I would be incredibly happy to pay commission to avoid being routed through a wholesaler. It appears evident that removing profiteering middlemen from the market would improve prices for household investors as well as institutions like pension funds. Citadel and similar companies cannot be the first to receive orders. Orders going to a public auction is a fundamental element of our markets; everyone, including pension funds, should have an equal opportunity to fill orders.