Mar. 30, 2023
To whom this may concern, The proposed revisions to ATS regulations and the SEC's efforts to enhance transparency in the routing of orders by brokers and wholesalers are consistent with the broader objective of promoting fair and transparent trading practices that would ultimately benefit individual investors. By mandating that ATS submit detailed disclosures regarding their operations, establish written policies and procedures to prevent fraudulent practices, and provide data on the execution of orders and order routing practices, the SEC would have better oversight and be able to ensure compliance with regulatory requirements. Additionally, the proposition to introduce a variable minimum pricing increment model for both quoting and trading of NMS stocks would foster equitable pricing across trading venues and create a level playing field for all investors, ultimately favoring household investors. The estimated savings for retail investors, which could range from $1.12 billion to $2.35 billion, primarily through increased competition to provide liquidity to marketable orders, underscore the importance of competition in regulating markets and removing obstacles to competition, such as the conflicting nature of PFOF. Furthermore, it is critical to prioritize creating a competitive market structure that benefits investors and promotes transparency. By imposing a cap on the high commissions or fees that brokers may levy instead of PFOF, the SEC can further diminish conflicts of interest and foster fair and transparent trading practices. Finally, the SEC must continue to identify and prevent fraudulent practices that undermine the credibility, integrity, and functionality of American markets, as such initiatives are widely supported by household investors. Overall, the proposed changes and initiatives by the SEC to increase transparency, minimize conflicts of interest, and foster fair and transparent trading practices are in alignment with the interests of household investors and are pivotal for establishing a competitive market structure that benefits investors and promotes transparency. Thank you for taking the time to read the comments of a concerned individual investor. Best, Daniel Abad