Mar. 07, 2023
March 7, 2023 \"To whom it may concern: As a household investor I am glad to see the SEC finally taking some action to reform markets to provide a more equal footing for all participants. These reforms are long overdue and would represent significant benefit in leveling the representation of household investors in the market. Citadel Securities, Charles Schwab Co. and NYSE Group claim they represent significant distinct aspects of the markets. To wit, there is effectively a duopoly of market makers (Citadel, Virtu), Charles Schwab Co.by revenue represents roughly 3.79% of market share and NYSE Group is one of the primary exchanges. As such, the assertion the respondents are making which appears to be one of representation of those most affected by the proposed reforms (household investors) is disingenuous at best. The primary interest the respondents have is one of material impact of the proposals creating a fairer market. Any organization which is or has near monopoly on an industry or sector will always view any change as one which harms it. I am deeply concerned that the proposals will not be implemented and or that they will be filled with sufficient loopholes to make them ineffective. The notion that the trading increment should differ from the quoting increment is somewhat preposterous. Effects of allowing this resoundly only benefit incumbent market participants or those with near monopolies from operating in even greater amounts in the dark markets. With regards to round-lots and odd-lots, the majority of household investors purchase via odd-lots and at the current time, they are not represented by the NBBO. Household stocks with significant investor activity are at a distinct and significant disadvantage by not having odd-lots represented in the SIP. Furthermore, incumbent and or large market participants are at a significant advantage to such stocks, or, in all fairness, all stocks, as only they are represented. Retail Auctions present a new and reasonable approach but far less than a complete ban on payment for order flow (PFOF). A complete ban on PFOF would be preferred. Having a single protocol by which said auctions occur allows for standardization, ease of maintenance, ease of compliance and ease of oversite. It would further allow for reductions in costs over time as all participants have a defined framework and protocol, instead of a multitude of different protocols, different standards and likely different outcomes. Citadel, NYSE and Charles Schwab would lead the commission to believe that adoption of the proposal (Retail Auctions) must wait or be indefinitely suspended in order to see if the effects of best execution are available. To this I would say, balderdash and poppycock. These firms are well aware of what the effects will be and are completely capable of modelling the data by themselves to understand the effects. Furthermore I would argue they already have. The SEC itself does not have a Best Execution rule, instead it relies upon FINRA and MSRB rules. Unfortunately, these bodies do not or are at least not viewed as representing household investors. The SEC maintains the broad authority over the market, as such it should have primacy and be the arbiter of what constitutes best execution. Citadel, Charles Schwab Co and NYSE Group would have the SEC believe that items such as conflicted transactions are impractical. The point of avoiding conflicts of interests is not to make things \"practical\", it is to make them fair and transparent. The assertion it may undo decades of progress for investors does not mean it will undo it for household investors, to be clear, they are clearly stating it will lessen the massive and unrestrained advantages they have enjoyed for decades. Regards, Michael Behrens Individual Investor\" I agree with Mr. Behrens.