Apr. 01, 2023
Hello, I am writing to voice my strong support for the newly proposed rule, File No. S7-29-22; Release No. 34-96493, regarding the Disclosure of Order Execution Information. As an individual investor, I understand the importance of Best Execution and the complexities involved in executing trades. Clear guidance on interpreting the data in Regulation NMS Rule 605 reports would greatly benefit retail investors who may not have a deep understanding of the markets. Brokers have a fiduciary obligation to provide Best Execution to their customers, and making it a rule that the SEC can enforce would ensure that brokers are held accountable. Conflicted orders should not be included in the Best Execution rule. 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. Recent charges against Robinhood by the SEC highlight the importance of enforcing the Best Execution rule. Robinhood made misleading statements and did not disclose payments received for routing trades to specific firms. Similarly, Citadel paid the SEC to settle Best Execution charges for executing customer trades at less favourable pricing when a better price was available. Quarterly reviews of execution quality would provide transparency and accountability for broker-dealers' practices. The proposed rule would establish a more detailed and comprehensive standard for broker-dealers to follow, resulting in consistently robust Best Execution practices. The proposed Regulation Best Execution is a necessary step in protecting household investors and promoting fair and efficient markets. Thank you for your attention to this matter. Sincerely, Riley Hume