Subject: File No. S7-18-23
From: Dominik

Dear Members of the Securities and Exchange Commission, I am writing to express my support for the proposed amendments outlined in Rule 6b-1, particularly regarding the prohibition of volume-based exchange transaction pricing for agency or riskless principal orders in NMS stocks. The proposed changes represent a step towards enhancing transparency and fairness within the financial markets. The first key aspect of the proposed rule, prohibiting equities exchanges from offering volume-based pricing for agency-related transactions, is a crucial measure to ensure market integrity. This restriction recognizes the need to eliminate potential conflicts of interest and promotes a level playing field for all market participants. The distinction made between agency-related volume and member proprietary volume is reasonable, allowing exchanges to maintain competitive pricing structures for proprietary trading while safeguarding against undue advantages in customer-related transactions. The inclusion of an anti-evasion clause is a prudent move to address potential circumventions of the intended restrictions. Requiring exchanges with volume-based pricing for member proprietary volume to adopt rules that prevent practices enabling non-compliance with the prohibition is a proactive step. Additionally, the establishment of written policies and procedures to detect and deter members from receiving inappropriate volume-based pricing for agency-related orders underscores a commitment to upholding the proposed rule. The third component of the proposed rule, mandating equities exchanges to electronically submit disclosures of the number of members qualifying for volume-based pricing, is a effort towards enhancing transparency. Making this information accessible to the public through the Commission's EDGAR system is a significant stride in promoting openness within the financial markets. It provides stakeholders, including investors, with valuable insights into how volume-based pricing benefits are distributed, facilitating more informed decision-making and contributing to an informed public discourse on market practices. In conclusion, I strongly endorse the proposed amendments to Rule 6b-1. The measures outlined are well-conceived and strike a balance between maintaining competitive dynamics and ensuring a fair and transparent marketplace. I believe that these changes will contribute significantly to the continued evolution of the securities market and enhance investor confidence. Thank you for considering my views on this matter. I appreciate the Commission's commitment to fostering a robust and transparent financial ecosystem. Sincerely, Dominik