Dec. 26, 2022
December 26, 2022
Dear Securities and Exchange Commission,
I am writing to express my support for the proposed amendments to Rule 605 of Regulation NMS, as outlined in S7-29-22. I believe that these changes will bring significant improvements to the transparency and fairness of order executions in national market system stocks.
Expanding the scope of entities subject to Rule 605 to include broker-dealers with a larger number of customer accounts, single dealer platforms, and entities that would operate qualified auctions will ensure that a wider range of market participants are held to the same standards of transparency and accountability. In addition, the proposed changes to the definition of \"covered order\" to include orders submitted outside of regular trading hours and with stop prices will provide a more comprehensive view of execution quality.
The proposed changes to the categorization of information required to be reported under the rule, including the inclusion of fractional share orders, odd-lot orders, and larger-sized orders, will provide a more detailed and accurate picture of execution quality. The elimination of time-to-execution categories in favor of average time to execution, median time to execution, and 99th percentile time to execution statistics will also allow for a more precise evaluation of execution quality.
Furthermore, the proposed enhancements to the required statistical measures of execution quality, including price improvement and size improvement statistics and measures of execution quality for non-marketable limit orders, will provide valuable insights for investors. The requirement for all entities subject to Rule 605 to make a summary report available will also make it easier for investors to access and understand this important information.
Overall, I believe that the proposed amendments to Rule 605 outlined in S7-29-22 will bring significant improvements to the transparency and fairness of order executions in national market system stocks, and I urge the Securities and Exchange Commission to move forward with their adoption.
Sincerely,
Nevin Varghese