Subject: File No. S7-10-21
From: N/A N/A
Affiliation:

Aug. 27, 2021



7. What would you like us to know about your experience with the features of your online trading or investment platform? (Examples of features are: social networking tools; games, streaks, or contests with prizes; points, badges, and leaderboards; notifications; celebrations for trading; visual cues, like changing colors; ideas presented at order placement or other curated lists or features; subscription and membership tiers; or chatbots.) 



Tradovate is an egregious offender of badges and awards for hitting 'milestones' set by the brokerage. 

Make first trade! 

Made first $x ! 

Made $x in a week! 



Horrible. 



Gamification (like above) should absolutely NOT be allowed in any brokerage.  Users are made to feel like milestones set for them by their brokerage indicates success or achievement.. Nothing could be further from the truth.  Brokers should not be in the business of gamifying as they have a huge incentive to compel users to trade. The more compulsive the trading the quicker the losses and greater the fees. 



Brokers should also be limited in what information they are allowed to put in front of their users.  Crypto currencies are not securities.. at least so the SEC mostly maintains.(mostly) Why then are brokers allowing access to them?  Why are brokers putting them so prolifically in front of their users? 





8. If you were trading or investing prior to using an online account, how have your investing and trading behaviors changed since you started using your online account? (For example, the amount of money you have invested, your interest in learning about investing and saving for retirement, the amount of time you have spent trading, your knowledge of financial products, the number of trades you have made, the amount of money you have made in trading, your knowledge of the markets, the number of different types of financial products you have traded, or your use of margin.) 



Of course!  I've been trading for 20 years... I never thought I'd use a phone for orders.. here we are. 



BUT AGAIN THE SEC IS MISSING THE MARK WITH THIS INVESTIGATION.  Gamification is a problem, but it's absurd to investigate when these brokerages are literally selling crypto digital imagination coin.. along with securities.. while claiming crypto is not a security.  The founders of those digital 'assets' make MANY false and fraudulent claims...with seemingly no oversight.  



YOU NEED TO INVESTIGATE CRYPTO NOW!  



If people are making millions or billions of dollars... and treating these digital assets as if they're securities.. with their initial coin offerings (stock IPOs), their obsession with price appreciation, charting just like stocks, selling it on securities brokers platforms.. etc.  then WHAT ARE YOU DOING TO PROVIDE OVERSIGHT?!  



Almost all of the crypto coins have failed to deliver on their initial promises, (fraud in many cases), often don't have any purpose except to scam investors, and, due to what can only be characterized as mass delusion, are price fluctuating at insane volatilities.. ...on margin in many cases.. on platforms and 'exchanges' which seemingly have no fiduciary or legal responsibility to their customers. 



The public is being fleeced left and right and the SEC won't characterize these 'assets' as securities even though that's exactly what they are. 



FOR THE LOVE OF GOD! Just read a whitepaper from any of the main crypto currencies.  READ IT. ...No one reads them. 



I have NOT been personally affected by this crypto currency mania but mass delusion only last so long. How many of our countrymen will be bankrupt?  How much electricity will be wasted? 



You need to 

1) Immediately classify crypto as a security.  The technology is absurd and, if it has any value, can easily be setup to be near free.  Contrary to popular belief, digital assets were made to be copied. All bits can be copied. The idea of scarcity is a myth or artificial requirement imposed to perpetuate the securitization of the technology. 



2) Enforce security laws on all US crypto exchanges 



3) Prohibit access and use to non-US crypto exchanges 



4) Immediately require Apple, and Google to limit all crypto apps from their online app stores until those 3rd party companies comply with US Security laws. (registration, licensure, oversight, etc) 



5) Immediately restrict bank transfers to crypto exchanges which are not compliant. Just like done for online gambling 



6) Directly address the public with clarity of purpose. 



The SEC has failed to protect investors as they've been scammed out of billions of dollars during this craze.  





10. What is your understanding, if any, of the circumstances under which trading or investing in your account can be suspended or restricted?  



My understanding is that an exchange has the power to restrict trading of an instrument.. and my broker/clearing has the power and fiduciary requirement to ensure I have the funds to trade an instrument.  THATS IT.  After brokers such as RobinHood restricted trading in the spring for certain securities it was an egregious overstep with clear conflict of interest to their duty to execute trades on their user's behalf.  People such as myself had cash in hand/account and were willing to buy instruments which were currently active on an exchange and the brokerages, because of their conflict of interest, were unwilling to allow purchases.  They blamed it on a clearing issue.. with number of days needed to clear obligations... which needs to be investigated because it is absurd.   





 11. What else would you like us to know – positive or negative - about your experience with online trading and investing? 



What's being missed... by the SEC.. IS THAT, after years of SEC involvement in ensuring fair markets using exchanges like the nyse, nasdaq, etc,  THE BROKERAGES HAVE BEEN ALLOWED to redirect orders to, what amounts to, private exchanges with no oversight. NBBO is routinely ignored by many of the prominent brokers who are routing their orders off exchange.  I almost always have orders sitting unfilled at my brokerage, etc. that would be filled if routed to an exchange properly. It's often the case, that my order does not fill until the competitive multi-exchange prices exceed by 2 ticks my order price. WHY DO YOU ALLOW THIS? 



ALL ORDERS should route to an exchange. So that all volume and fills can be clearly visible to the public. in a timely manner.  Do this, enforce it, and many of the problems encountered by bad actors in the brokerage/routing/clearing market resolve themselves.