October 18, 2021
Proposed rule 7.13 does not appear to create a fair/transparent market. By providing the CEO/Chair the ability to suspend trading whenever in his/her opinion such suspension would be in the public interest, there is too much room for bias and or corruption. Considering a chairperson on NYSE may potentially have financial incentive to suspend trading in a given security, this rule provides them with a tool capable of being abused.
Example given: Ken Griffin (of Citadel Securities) has donated $3 million to GUV (political PAC). The same political PAC which heavily funded the election campaign of Senator Loeffler. This particular Senator is married to Jeffrey Sprecher, the chairman of NYSE. This can easily be seen as Ken Griffin, the owner of a very large Designated Market Maker (Citadel Securities), buying favors from NYSE leadership. This leaves other market participants at a disadvantage as the NYSE CEO/Chair can suspend trading anytime they so please for public interest.
This new rule (7.13) should not be implemented. Instead, dark pool trading should ceased as it does not allow for equal and transparent market participation.