Subject: File No. S7-29-22; Release No. 34-96493; Disclosure of Order Execution Information
From: Michael Montalban
Affiliation:

Mar. 31, 2023



To whom it may concern: 



The proposed changes to Rule 605 of Regulation NMS are meant to improve the information provided about broker executions, but it's frustrating to see that brokers are already failing to comply with the current reporting requirements. It's been over two decades since SEC Rules 605 and 606 were introduced, yet brokers are still publishing inaccurate information on order routing and making incomplete disclosures about their relationships with disclosed venues. 

FINRA and the SEC issued risk alerts in December 2022, but it's doubtful that brokers will improve their compliance with the new 605 reports. After all, the accuracy of the data contained within these reports is crucial to their usefulness, and it's evident that brokers have been unable or unwilling to provide accurate information so far. This lack of compliance will likely result in little to no benefit for retail investors, which is frustrating given the original intention behind these rules. 


Thank you, Michael