Mar. 31, 2023
To whom it may concern, I am in support of this rule as a household investor, and believe it will make the US stock market a more equitable and fair place to invest. I am a foreign investor based in the UK with a very keen interest in US companies who lead globally in their domains. The current state of the market is flawed, and rules like the order competition rule are key to ensuring the integrity, credibility and functioning of the american markets. The SEC should increase transparency in the routing of orders by brokers and wholesalers, with investors having access to the best priced quotations available in the NMS, in order to reduce conflicts of interest. This would help to ensure that investors receive the best execution possible for their trades. The proposed changes to ATS rules would promote better alignment with regulatory frameworks for exchanges, which would be beneficial for individual household investors. ATS should submit detailed disclosures about their operations, including how they manage conflicts of interest, how they operate their order routing practices, and how they handle customer orders. This would make it easier for investors to understand how ATS operate and how their orders are executed. ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices, which would help to protect individual investors from abusive practices in the ATS market. Additionally, ATS should provide detailed information about the operation of their systems to the SEC, including data on the execution of orders, order routing practices, and information about the use of dark pools. This would improve the SEC's ability to oversee ATS and ensure compliance with regulatory requirements. ATS should operate in a manner that is consistent with the broader regulatory structure of the securities markets, which would benefit individual investors by promoting fair and transparent trading practices. This would include implementing a variable minimum pricing increment model for both quoting and trading of NMS stocks, which would promote fair pricing across trading venues and ensure a level playing field for all investors. Household investors support any initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. Therefore, the SEC should prioritize creating a competitive market structure that benefits investors and encourages transparency. Finally, sending orders to a wholesaler for internalisation should not be the only option available to investors. Brokers may charge high commissions or fees in lieu of PFOF, so a cap should be implemented. Sincerely, Daniel Powell