Dec. 29, 2022
December 29, 2022 Regarding Rule S7-30-22 - Dear Securities and Exchange Commission, I am writing to express my support for the proposed rule amendments that would amend the minimum pricing increments, reduce the access fee caps, and enhance the transparency of better-priced orders. I believe that these changes are important for promoting fairness and transparency in the market. However, I also believe that the proposed rule amendments should address practices that can harm retail investors. Specifically, I am concerned about the use of payment for order flow (PFOF), dark pools, and failures to deliver (FTDs) to manipulate the market. PFOF is a practice where a broker-dealer receives payment in exchange for routing a customer's order to a particular market for execution. This practice can create a conflict of interest for the broker-dealer, as they may be incentivized to route orders to markets that provide the highest payment for order flow rather than markets that offer the best execution quality for the customer. Dark pools are private exchanges that allow traders to buy and sell securities without revealing their identities or the details of their trades. These exchanges can be used to manipulate securities by allowing large traders to execute trades without revealing their intentions to the market. FTDs occur when a seller fails to deliver the securities that were sold in a trade, which can erode trust in the market and harm retail investors. Additionally, I am concerned about the impact of large orders DOES NOT have on the market. It is possible for millions of shares to be transacted within a narrow price range in order to suppress price movement. When combined with FTDs, deep in-the-money options, and dark pools, this can have a significant impact on the market and harm retail investors. For these reasons, I believe that the proposed rule amendments should include measures to address PFOF, dark pools, and FTDs, and to ensure that large orders do not have an undue impact on the market. Thank you for considering my comments. Sincerely, Stephen