Subject: Re: Order Competition Rule, File No. S7-31-22, Release No.34-96495
From: Conor Stratton
Affiliation:

Mar. 31, 2023



To Whom It May Concern,

As an individual household investor, I thank you for your effort to create more competition and transparency in the market, and I appreciate the chance to comment on these proposals.

In aggregate, these recommended enhancements constitute one of the most significant changes to U.S. equity market structure since Regulation NMS was implemented in 2005.

Investors should have access to the best priced quotations available in the national market system and prices should, in general, be determined by competitive market forces.

It shouldn’t be possible to pay billions of dollars for retail orders for the ability to control everything in that entire market.

Citadel recommended withdrawing this proposal for a number of reasons, including the unprecedented nature of requiring certain market participants to utilize a specific trading protocol.

Sending my orders to a wholesaler to be internalized is a specific trading protocol that I’d rather to avoid. A wholesaler such as Citadel shouldn’t have a monopoly on retail order flow.

My concern is that brokers will start charging outrageous commissions or fees in lieu of PFOF, so I’d recommend a cap on the amount of commissions or fees that the brokers are allowed to charge.

I trust the Economic Analysis done by the commission and I look forward to retail saving from $1.12 billion to $2.35 billion on transaction costs.  These estimated gains would be generated primarily through increased competition to supply liquidity to marketable orders of individual investors, which in turn would lower transaction costs for individual investors, potentially enhance order execution quality for institutional investors, and improve price discovery.

Thank you for your time,

Conor Stratton