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

Mar. 31, 2023

 


Good afternoon I am an investor in the US stock market and am reaching out pertaining to the way orders are processed and market makers interact with the stock market. As such I am sending this email specifically to comment and offer my support on the referenced rule in the subject line: File No. S7-31-22; Release No. 34-96495: Order Competition Rule.  

I thank you for the opportunity to allow myself and others to comment on rules such as these. In order to communicate my thoughts clearly and precisely I have listed below key bullet points around my concerns that this rule addresses: 


- I am in support of rule changes that enforces order routing to the open market where a public auction takes place to fill an order. As such market makers like Citadel should not be allowed to be the first in line to fill an order. 
- I am in support of the UK's rules to ban PFOF as a whole and support the US market doing so as well. This is primarily fueled by the fact that investors such as myself are victims of practices that are in clear violation of FINRA's Best Execution guidance when dealing with brokers that utilize PFOF. This rule change is a step in the right direction. 
- Additionally participants in the market who routinely break laws that issue only, relative to the funds profited, small fines need to be punished appropriately to discourage the use of these loopholes to create profit illegally. Fines should be more proportional to the total number of funds involved with an illegal transaction and exponential with each subsequent occurrence leading to possible removal of the market altogether through loss of license. Any punishment for illegal practice in the market should not be considered insignificant enough to be thought of as the "cost of doing business". 

I am happy to see the SEC taking steps to better regulate and balance the exchange and hope to see this rule implemented soon. 

- David Wright