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

Apr. 01, 2023



Dear SEC,

I am writing to express my support for File No. S7-29-22; Release No.
34-96493· Disclosure of Order Execution Information. I believe that
this proposed rule is necessary to protect household investors and
promote fair and efficient markets by ensuring that they are receiving
the best possible execution for their trades.

Best execution is essential in trade execution, especially for
individual investors who may not understand the complexities involved
in choosing how to execute a trade. Brokers owe their customers a duty
of Best Execution derived from common law agency principles and
fiduciary obligations. However, it needs to become a rule that the SEC
can enforce to ensure that brokers are acting in the best interest of
their customers.

I urge the SEC to provide clear guidance on how to read and interpret
the data in Regulation NMS Rule 605 reports, especially for retail
investors who may not have a deep understanding of the markets.
Different trading venues may offer different prices, slower execution
can lead to missed opportunities, and less reliable settlement
processes can delay receipt of proceeds. 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.

Conflicted orders don't belong in a Best Execution rule. Quarterly
reviews of execution quality would provide transparency and
accountability for the broker-dealers' practices. The proposed rule
would provide a more detailed and comprehensive standard for
broker-dealers to follow, resulting in consistently robust best
execution practices.

I would like to draw your attention to the cases of Robinhood and
Citadel, which were charged by the SEC for failure to satisfy their
best execution obligation, resulting in a significant loss of money
for their customers. Robinhood made misleading statements and did not
disclose payments received for routing trades to specific firms.
Citadel paid the SEC $22.6 million in 2017 to settle best execution
charges for executing customer trades at less favorable pricing when a
better price was available. Brokers recommending mutual funds with
12b-1 fees and revenue sharing arrangements with clearing brokers have
also faced best execution charges from the SEC.

In conclusion, I strongly support the proposed regulation, and I
believe that it is a necessary step in protecting household investors
and promoting fair and efficient markets. I urge the SEC to implement
this proposed rule as soon as possible to ensure that all investors
receive the best possible execution for their trades.

Thank you for considering my views.