Mar. 31, 2023
Dear Sir/ Madam, I fully support the proposed Regulation Best Execution rule by the SEC, which aims to strengthen investor protection by requiring brokers to provide the best possible execution for their trades. This proposed rule is especially crucial for individual investors who may not understand the complexities involved in trade execution. Brokers owe their customers a duty of best execution derived from common law agency principles and fiduciary obligations. However, making it a rule that the SEC can enforce will help ensure that investors receive the best execution possible, free from conflicted orders. The proposed rule would also provide clear guidance on how to read and interpret the data in Regulation NMS Rule 605 reports. This is especially important for retail investors who may not have a deep understanding of the markets. Quarterly reviews of execution quality would also provide transparency and accountability for the broker-dealers' practices. Without the best execution rule, customers may not be aware of revenue arrangements between brokers and subpar trading firms or that they 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. Recent charges against Robinhood, Citadel, and brokers recommending mutual funds with 12b-1 fees and revenue sharing arrangements highlight the need for a more detailed and comprehensive standard for broker-dealers to follow. The proposed rule would provide consistently robust best execution practices and promote fair and efficient markets. In conclusion, the proposed Regulation Best Execution is a necessary step in protecting household investors and ensuring they receive the best possible execution for their trades. It would also provide much-needed transparency and accountability for broker-dealers' practices. I urge the SEC to adopt this proposed rule to strengthen investor protection and promote fair and efficient markets. Sincerely, Jason Karkiewicz Jason Karkiewicz KOTE INSTRUMENT SERVICE