Mar. 31, 2023
Dear SEC, I am writing to express my strong support for the proposed Regulation Best Execution. As an individual investor, I understand the importance of receiving the best possible execution for my trades, and I believe that the proposed rule would be a significant step in protecting household investors and promoting fair and efficient markets. One of the key issues that the proposed rule seeks to address is the lack of clear guidance on how to interpret the data in Regulation NMS Rule 605 reports, especially for retail investors who may not have a deep understanding of the markets. Providing clear guidance on how to read and interpret these reports would be a significant step towards ensuring that individual investors are receiving the best possible execution for their trades. Furthermore, brokers owe their customers a duty of Best Execution derived from common law agency principles and fiduciary obligations, but it needs to become a rule that the SEC can enforce. Conflicted orders don't belong in a 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. The proposed rule would also require brokers to conduct quarterly reviews of execution quality, providing transparency and accountability for their practices. This would help to ensure that individual investors are receiving the best possible execution for their trades and that brokers are held accountable for their actions. Recent cases such as Robinhood being charged by the SEC with failure to satisfy its best execution obligation and Citadel paying the SEC to settle best execution charges highlight the need for a more detailed and comprehensive standard for broker-dealers to follow. The proposed rule would provide this standard, resulting in consistently robust best execution practices. In conclusion, the proposed Regulation Best Execution is a necessary step in protecting household investors and promoting fair and efficient markets. It would provide clear guidance on how to interpret trade execution data, ensure that brokers are held accountable for their practices, and provide a more detailed and comprehensive standard for broker-dealers to follow. I urge the SEC to adopt the proposed rule as soon as possible. Thank you for considering my comments. Sincerely, A Concerned Investor