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

Mar. 31, 2023




- I support this rule as it protects all participants of the market by upholding equality when it comes to executing the best possible trade. 



- For individual investors who may not understand the complexities of trade execution, best execution is crucial. 
- Clear guidance should be provided on how to interpret Regulation NMS Rule 605 reports, particularly for retail investors who may not be well-versed in the markets. 
- While brokers have a duty of Best Execution based on common law agency principles and fiduciary obligations, it needs to become a rule that the SEC can enforce. 
- A Best Execution rule should not include conflicted orders. 
Without a Best Execution rule, customers may not be aware of revenue arrangements between brokers and subpar trading firms, leading to higher transaction prices. 
- Different trading venues may offer different prices, so slower execution can lead to missed opportunities, information leaks can inhibit transactions, and less reliable settlement processes can delay receipt of proceeds. 
- In December 2020, Robinhood was charged by the SEC with failing to meet its best execution obligation, resulting in a $34.1 million aggregate loss for its customers. 
- Robinhood made misleading statements and did not disclose payments received for routing trades to specific firms. 
- Citadel settled best execution charges with the SEC in 2017, paying $22.6 million for executing customer trades at less favorable pricing. 
- Brokers recommending mutual funds with 12b-1 fees and revenue sharing arrangements with clearing brokers have also faced best execution charges from the SEC. 
- Quarterly reviews of execution quality would increase transparency and accountability for the practices of broker-dealers. 
- The proposed rule would provide a more detailed and comprehensive standard for broker-dealers to follow, resulting in consistently robust best execution practices. 
- The proposed Regulation Best Execution is necessary to protect household investors and promote fair and efficient markets by ensuring that household investors receive the best possible execution for their trades. 

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