Mar. 31, 2023
To Whom it May Concern, Thank you for your time in reading and considering this letter- I am a household investor and small business owner. I believe that in order to build on the hard work I’ve invested in my business and my community - to have something to pass down to my children - and to invest in my own security for the future, that the financial markets must work fairly and in a way that ensures equal access and opportunities for all market participants. It has become clear through my observations of the markets over the past years that there are numerous ways in which large financial interests have continually gained numerous advantages, engineered or accessed legal loopholes, and created systems that inherently disadvantage household investors: the very people who makeup the moral and market fabric of our society are being exposed to a system that inherently works to extract the hard earned wealth that every day people are investing their lives into earning. It is with this thought in mind that I want to speak today in regards to disclosure of order execution information. Ultimately I believe that was is best for the investors who participate in our markets is that it is transparent, applies consistently to all participants, does not foster or encourage the existence or creation of back doors or privileged status to one or few parties, and that the penalties for violations are swift, severe, and deterrent to potential violators. With that in mind I support this proposal today to help ensure better transparency for all market participants. Best execution is a vitally important component of a fair market and we need to have clear guidance from the commission on how to read and understand the data in regulation NMS Rule 605 reports. This should be designed around making the information digestible to as many parties as possible - prioritizing clarity. I don’t want to see conflicted orders in a best execution rule, we think brokers OWE their customers a duty of best execution but also want to see this become a truly enforceable rule. Additionally that requires that these rules apply equally to all exchanges, brokers, participants etc. Best execution needs to be a standardized enforceable action that is clear to every participant through out every segment. Making reviews of the execution quality quarterly will help make sure this rule is functioning well. I want to see this proposed rule enacted as it will enhance transparency and accountability for market participants and in light of many recent failures of disclosure like Robinhood in December 2020, Citadel in 2017 (Paying 22.6 million in poorly executed trades - must be enacted as this is clearly an area of issue in today’s markets. Thank you for your consideration and desire to make our markets more free and fair- Alex