Subject: RE: File No. S7-29-22; Release No. 34-96493· Disclosure of Order Execution Information
From: Roxanne Barrionuevo
Affiliation:

Mar. 19, 2023

 


To Whom It May Concern: 



In order for SEC rules to have real impact, they need to be enforced effectively. One way to deter unethical practices is to impose significantly higher fines and revoke the licenses of broker-dealers who engage in such behavior. Otherwise, Broker-dealers will continue to break the rules in place and justify it as a “cost of doing business.” I fully support this proposed rule and urge that it be implemented quickly.


There are some practices in the American markets that undermine their integrity, credibility and functioning. For example, offering incentives and giving certain big players and unfair advantage over others. The current system, where orders go through many intermediaries, is unnecessarily complex and lacks transparency. Brokers should be required to route orders directly to the auction and specify alternative routes if necessary to level the playing field.


In the US securities markets, fair competition is ESSENTIAL. However, a few off-exchange systems have created a monopolistic environment that harms investors and undermines market integrity. The proposed rule is an important step towards restoring fair competition and increasing transparency in these dark markets. The SEC needs to be more vigilant in ensuring that brokers and dealers operate within a level playing field.


I would much rather pay a higher fee per share than to have my orders routed through wholesalers that have repeatedly violated securities laws. These wholesalers have significant conflicts of interest and undue influence over other market participants. There are studies that show that internalization harms market quality and results in poor execution for investors. Removing these profiteering middlemen from the market can benefit individuals and institutions (e.g.: pension funds) through improved pricing and savings. 



The proposed rule aims to simplify and enhance transparency in the American markets by eliminating intermediaries, reducing fragmentation, and preventing these monopolistic practices. I support this initiative because it aligns with my preference for a free and transparent market structure that benefits all participants, not just a few dominant players.


Regards,
Roxanne Barrionuevo