Subject: File No. S7-10-21
From: Anonymous

November 18, 2021

1. Do you have one or more online trading or investment accounts?
Yes, I have one or more accounts that I access both online using a computer and using a mobile app.

2. If your response to Question 1 is Yes, do you think you would trade or invest if you could not do so online using a computer or using a mobile app?
No

3. On average, how often do you access your online account?
Daily/more than once a day

4. On average, how often are trades made in your online account, whether by you or someone else?
Once to a few times a week.

5. If you access your account online, did you have the account first, and only began to access it electronically later? Or did you open the account with the idea that you would access it electronically immediately?
I downloaded an app or visited a website first, and then opened up an account with the company

6. My goals for trading or investing in my online account are (check all that apply):
Save and grow my money for short-term goals (in the next year or two)

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.)
Ive noticed that information/articles is presented in a certain way that seems to trigger an investment decision. For example repeatedly seeing an article title Is go pro 47% undervalued? Over the course of several days. Additionally it seems my data is used to bias search results when attempting to research a topic that was presented to me within my brokers app (Robinhood). The privacy policy allows for sharing of my data but the implementation of the privacy policy is not transparent and defaults to allow data sharing, and you must go check the privacy/security settings to even see its an option. Its clear as day aggregated data is being used to test behavioral strategies and implement them to attempt to predict aggregate trade decisions while limiting the ability for users to easily verify the information outside of the app (ex. 1st page search results on google confirm the info presented in the app). If thats true it should be an egregious legal violation but Im sure everything theyre doing is technically legal

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.)

9. How much experience do you have trading or investing in the following products (None, 12 months, 1-2 years, 2-5 years, 5+ years):
Stocks : 2-5 Years
Bonds : None
Options : 1-2 Years
Mutual Funds : None
ETFs : 2-5 Years
Futures : None
Cryptocurrencies : Less Than 12 Months
Commodities : None
ClosedEnd Funds : None
Money Market Funds : None
Variable Insurance Products : None
Business Development Companies : None
Unit Investment Trusts : None

10. What is your understanding, if any, of the circumstances under which trading or investing in your account can be suspended or restricted?
I dont use margin but I understand if I did that my brokerage can suspend/restrict my account if my positions lead to a deficit

11. What else would you like us to know positive or negative - about your experience with online trading and investing?
Online trading reduces barriers to entry for retail investors and I believe this to be overall positive, with anything you want to learn theoretically being readily available. There is a massive risk of retail investors being abused in ways that arent easily apparent via data collection, sharing, and then providing that data to 3rd parties who then target/curate information that limits what is readily available to the investor and/or actively attempts to lead an investor to make a predictable investment decision, reduce their ability to see any alternative, or downplay negative and opposing views of a bias set of targeted/curated information. This can easily cause new investors to be led to giving their money away to a more sophisticated predatory firms operating with inside information on them without their knowledge.

This is most easily solvable with robust data and privacy rules for brokers and transparency around what specifically is being collected, how its collected, how its used, who can use it and with what stipulations, rules around opting into sharing data, and rules governing what they can collect/share/aggregate in the first place.

Where it gets more difficult is that data is collected by countless parties, aggregated, and used in ways we cant transparently see and understand. Data on individuals needs to be regulated across all online services.

At least specifically relating to retail investing broker apps, its clear a large problem can be solved by starting with data regulation here at the source since they can collect data 1st party on what transactions you make, information/articles youve interacted with in app, and what the actions were after that. All this is allowed to be shared with 3rd party analytics firms that can combine that with user interactions outside the broker app according to the privacy policy which you dont any options to say no to and are automatically opted into without understanding the implications of.