Mar. 30, 2023
Dear rule makers, The SEC's proposed changes to ATS rules and focus on increasing transparency in the routing of orders by brokers and wholesalers support the broader goal of promoting fair and transparent trading practices that ultimately benefit individual investors. The proposed requirements for ATS to disclose detailed information about their operations, establish written policies and procedures to prevent fraudulent practices, and provide data on the execution of orders and order routing practices will enhance regulatory oversight and compliance. Implementing a variable minimum pricing increment model for both quoting and trading of NMS stocks would also promote fair pricing across trading venues and create a level playing field for all investors, ultimately benefiting household investors. The estimated savings for retail investors, ranging from $1.12 billion to $2.35 billion, demonstrate the importance of competition in regulating markets and removing barriers to competition, such as the conflicted nature of PFOF. To further reduce conflicts of interest and promote fair and transparent trading practices, the SEC should implement a cap on high commissions or fees brokers may charge instead of PFOF. Creating a competitive market structure that benefits investors and encourages transparency should be a priority. Additionally, the SEC should 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. In summary, the SEC's proposed changes and initiatives to increase transparency, reduce conflicts of interest, and promote fair and transparent trading practices align with the interests of household investors. These efforts are crucial for creating a competitive market structure that benefits investors and encourages transparency. Regards, Tristan Mayer Periard Junior Developer