Mar. 15, 2023
March 15, 2023 I cannot support this rule unless the exceptions for risk-mitigating hedging activities, bona fide market making certain liquidity commitments are removed. I cannot understand how our markets could be classified as \"fair\" if conflicts of interest prohibitions are not applied to all players in the market. All market participants should be required (and verified via reporting) to avoid conflicts of interest, not just smaller market participants. Additionally, common reporting for all players, in a timely manner (at end of day, as opposed to 15 days later), is required to ensure equal information is available to all market participants. Timely disclosure and accurate information is required for efficient price discovery on securities. Finally, \"Market making\" and \"providing liquidity\" are at the very top of my list for concerns about conflict of interest. \"Providing liquidity\" ,as practiced by the current market makers, adds unfounded supply. In my opinion, this should be prohibited absolutely (in order to facilitate price discovery), but at a MINIMUM, if it is to be allowed, it must be clearly demonstratable and verifiable to be free from Conflicts of Interest. Existing market makers have been cited for failing to follow the rules many times over the past few years... I do not see this as an area where depending on self regulation has shown to be effective in the past.