Mar. 31, 2023
To Whom It May Concern, I am writing this email as an individual household investor in strong support of the Order Competition Rule. Major market participants such as Citadel and Virtu are clearly benefiting from the current landscape in which payment for order flow (PFOF) is permitted. Broker-dealers' ability to internalize retail orders hampers price discovery of securities and is a blatant conflict of interest that should be banned in the US as it is in the UK for the sake of the integrity, credibility and functioning of American markets. Furthermore, the fragmentation of the markets into "lit" and "dark pools" complicates the markets in ways that only benefit large players, leaving household investors at a disadvantage. In addition to support for immediate implementation of this rule, I also support steep and escalating penalties for violations of the rule including loss of broker-dealer licensure for repeat and/or large-scale violations. When fines are miniscule in comparison to the profit that can be made by breaking the law, they become a mere cost of doing business. Fines and other consequences must be severe enough to serve as a deterrent. In closing, I wholeheartedly support requiring brokers to first route orders to public auction to ensure transparency and best execution price. Catherine Wells