Subject: RE: File No. S7-29-22; Release No. 34-96493· Disclosure of Order Execution Information
From: Matt Pearce
Affiliation:

Mar. 31, 2023




Good Afternoon, 


Hope you are well! Please see below comments: 



Citadel and Virtu utilise a "price improvement scheme" to attract order flow by claiming to offer the best trades in the market. While their performance statistics seem to support this, they often do not provide the best price available, but rather a slightly better price. This allows them to gain order flow without needing to pay for order flow. There is a suspicion that they selectively apply the price improvement to benefit themselves. The new rules aim to enforce legal requirements that should have already been in place and mandate more transparent disclosure of their practices to prevent deception. This will help to expose any unethical behaviour and prevent them from taking advantage of the market. I FULLY support this rule. 

Thank you! 

Matt