Mar. 31, 2023
Dear Sir/Madam, As a household investor, I support the proposed Regulation Best Execution under File No. S7-29-22; Release No. 34-96493. I believe that best execution is critical in trade execution, and it is essential that I receive the best possible execution for my trades. I often find the market complexities overwhelming, and clear guidance on how to read and interpret data in Regulation NMS Rule 605 reports would be helpful, especially for retail investors like myself who may not have a deep understanding of the markets. Brokers owe me and those investors like me a duty of Best Execution derived from common law agency principles and fiduciary obligations. However, it is important that this duty becomes a rule that the SEC can enforce. Conflicted orders don't belong in a Best Execution rule, and without it, I may not be aware of revenue arrangements between brokers and subpar trading firms or that I may be paying higher transaction prices. Different trading venues may offer different prices, and slower execution can lead to missed opportunities. Information leaks can inhibit a successful transaction, and less reliable settlement processes can delay receipt of proceeds. It is crucial that my broker provides consistently robust best execution practices. The proposed Regulation Best Execution would provide a more detailed and comprehensive standard for broker-dealers to follow, resulting in increased transparency and accountability for their practices. Quarterly reviews of execution quality would give me the assurance that I am receiving the best possible execution for my trades. The recent charges against Robinhood by the SEC for failure to satisfy its best execution obligation, resulting in an aggregate loss of $34.1 million for its customers, demonstrate the importance of this proposed rule. Citadel's payment of $22.6 million in 2017 to settle best execution charges and brokers charged with best execution violations for recommending mutual funds with 12b-1 fees and revenue sharing arrangements further highlight the need for increased oversight and regulation. Overall, I believe that the proposed Regulation Best Execution is a necessary step in protecting me as a household investor and promoting fair and efficient markets. Sincerely, Christopher Sheehan Household Investor