Subject: S7-29-22: WebForm Comments from Zachary M. Bruner
From: Zachary M.Bruner
Affiliation:

Mar. 30, 2023

March 30, 2023

 Expand the scope of entities subject to rule 605 by requiring broker dealers with a larger number of customer accounts, single dealer platforms, and entities that would operate qualified auctions being proposed separately in an order competition rule to make available to the public monthly execution quality reports
amend definition of covered order to include certain orders submitted outside regular trading hours in certain orders submitted with stop prices
amend the categorization of information required to be reported under the rule, including changing the order type categories in the order size categories to include fractional share orders, odd lot orders, and larger sized orders
eliminate time to execution categories in favor of average time to execution, median time to execution, and 99th percentile time to execution statistics, each as measured in increments of a millisecond or finer
amend the information required to be reported under the rule, including changing the realized spread statistics to 15 second and one minute realized spread and require new statistical measures of execution quality that could be used to evaluate price improvement and size improvement for all order types, additional price improvement statistics for market and marketable order types, and certain statistical measures that could be used to measure execution quality and non marketable limit orders
enhance the accessibility of the required reports by requiring all entities subject to rule 605 to make a summary report available