Mar. 31, 2023
This rule is critical to me as a retail investor and to retail investors everywhere. Orders being routed directly to Citadel's internal systems, or other market makers, is in direct conflict with individual's interests. Broker's who don't accept payment for order flow route orders differently and therefore see higher quality order execution. Additionally, recent studies show that brokers such as Robinhood don't provide any price improvement. Retail investors who aren't forced to deal with payment for order flow get a better price than those dealing with payment for order flow. Payment for order flow is in direct violation of FINRA's Best Execution guidance. The state of American markets is anti-competitive and the Commission needs to ensure fair competition, especially when dealing with off-exchange systems that are currently plaguing the market space for retail investors. There's a reason payment for order flow has been banned in the UK due to conflicts of interest. The same should be true for the United States. Citadel's payment for order flow is becoming monopolistic and the Commission needs to ensure fair competition and remove middleman profiteering from the market. Enforcement of SEC rules needs to be improved with higher fines to serve as a significant deterrent for breaking the law. In the current environment, these fines seem more like "costs of doing business" when violators still retain profit even after paying any requisite fines. Thank you, Jeff Martin