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

Mar. 31, 2023

 



I'm writing in support of File No. S7-31-22, Release No.34-96495. As a US citizen, I support rules that support a fairer market structure, which I believe this rule is helping to build upon. I've reviewed this proposed ruling and I especially support the portion of the ruling involving investor NMS orders being routed to an auction house before other market players get the orders. This proposed structure is in my opinion fairer, and one that I support. 


I fully support the rule, please implement it as soon as possible. I deeply appreciate and support any efforts to reduce inducements and to reduce the ‘farming’ of individuals’ orders for rebate money. 



A broker who routes orders first to a wholesaler, who then passes them to an auction, which might route it back to the wholesaler, seems unnecessarily complex and also grants the wholesaler a profound information advantage against other market participants: they get to see orders well before anyone else. How is that fair? The Commission should address this unfair information advantage by having brokers first route to the auction. 



Fragmentation of the markets makes things overcomplicated in a way that only benefits large, dominant players. I prefer a more simple, transparent, and free market structure like the one proposed in this rule. 



Thanks for reading, 
Timothy McDermott