Mar. 31, 2023
Dear Chairman Gensler, I am writing in support of the proposed Order Competition Rule (the "Rule"), which was released by the U.S. Securities and Exchange Commission on January 19, 2022 (Release No. 34-96495). I believe that the Rule is a necessary step towards promoting competition in the securities markets, which will ultimately benefit investors and the overall economy. The Rule would require national securities exchanges to adopt rules that promote fair and open access to their data feeds and other market data, which would in turn enable market participants to compete on a level playing field. As an individual investor, I have personally experienced the challenges of accessing and interpreting market data, particularly in an environment where larger market participants may have an advantage. The Rule would help to level the playing field and make it easier for all investors to participate in the markets. It has been proven again and again that brokers not accepting any kind of PFOF route orders differently and consequently see superior execution quality. Indeed, a recent study found that Robinhood does not provide statistically significant price improvement relative to exchanges, despite PFOF being responsible for around 70% of its revenue. I believe that the Rule strikes an appropriate balance between promoting competition and ensuring that national securities exchanges continue to operate in a safe and sound manner. The proposed requirements are reasonable and necessary to achieve the Rule's intended objectives, and I believe that they will ultimately benefit all market participants. Thank you for considering my comments on this important issue. I urge the Commission to adopt the proposed Rule, and I look forward to its implementation. Sincerely, David Daumas