Subject: Re: Rule Proposal No. 34-96496; File No. S7-32-22 Regulation Best Execution and Rule Proposal No. 34-96494; File No. S7-30-22 Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders
From: Michael Shawn Montgomery
Affiliation:

Mar. 15, 2023

  


Dear Ms. Countryman
I am writing to express my concern regarding the practice of payment for order flow in the securities industry. As a citizen and investor, I strongly believe that payment for order flow is a conflict of interest that harms individual investors and undermines the integrity of the securities market.
Payment for order flow refers to the practice of brokerages receiving compensation from market makers for directing client orders to them. While this practice may appear harmless on the surface, it creates a clear conflict of interest for brokers who may be incentivized to route orders to market makers that offer the highest payment, rather than the best execution for their clients.
Furthermore, payment for order flow results in less transparent pricing and reduced competition in the securities market. When brokerages are paid for order flow, they have less incentive to search for the best prices and execution for their clients, as they are already receiving compensation from market makers. This can lead to worse execution prices for individual investors, who may not be aware of the details of their brokerage's payment for order flow arrangements.
In my opinion, payment for order flow is bad for the securities industry and should be prohibited. I strongly urge the Security and Exchange Commission to take action to end this practice and promote a fair and transparent market for all investors.
Thank you for your attention to this important matter.
Sincerely,
Michael Shawn Montgomery