Subject: S7-31-22
Form Type L
Dear Ms. Countryman:
As an individual retail 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.
Order Competition Rule S7-31-22
Investors should have access to the best priced quotations available in the national market system and such prices generally should 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 pay commission to be able to avoid. A wholesaler such as Citadel who has been front-running customer orders since 2006 shouldn’t have a monopoly on retail order flow. My only 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. I think it’s imperative that the Commission take these steps in order to start gaining back confidence and trust from the public. Seeing what happened with Gamestop eroded Investor Confidence so much that Investors have been taking their shares out of the system to hold them with the Transfer Agent. I’m sure my letter will be carefully considered, and I want to again thank you for the opportunity to comment.
Thank you,
Sources that I cited on my letter (Gensler said he wanted DATA!):
https://www.finra.org/media/document/11737
https://www.finra.org/rules-guidance/rulebooks/finra-rules/5310
https://www.cfainstitute.org/-/media/documents/article/position-paper/payment-for-order-flow-united-kingdom.ashx#:~:text=Payment%20for%20order%20flow%20(PFOF)%20is%20the%20practice%20of%20market,order%20flow%20by%20market%20makers%20is%20the%20practice%20of%20market,order%20flow%20by%20market%20makers)
https://www.finra.org/rules-guidance/guidance/reports/2022-finras-examination-and-risk-monitoring-program/disclosure-routing-information
https://www.sec.gov/rules/final/34-43590.htm#secv
https://www.finra.org/rules-guidance/guidance/reports/2022-finras-examination-and-risk-monitoring-program/disclosure-routing-information
https://www.sec.gov/files/reg-nms-rule-606-disclosures-risk-alert.pdf
https://www.thetradenews.com/citadel-securities-forks-out-2-6-billion-annually-for-payment-for-order-flow-and-most-of-its-on-options/
https://files.brokercheck.finra.org/firm/firm_116797.pdf
https://www.merriam-webster.com/dictionary/monopoly
https://www.sec.gov/rules/proposed/2022/34-96495.pdf
https://www.sec.gov/rules/final/2020/34-90610.pdf
https://press.princeton.edu/ideas/how-to-make-money-in-nanoseconds
https://news.gamestop.com/static-files/5a610aaf-6606-4173-86a1-cba6abdb204a