Mar. 15, 2023
Dear Ms. Countryman, As an educated professional and an advocate for investor interests, I appreciate the opportunity to provide my comments on the SEC's Best Execution Proposal and the NMS Proposal. My focus lies on three key principles: Transparency, Simplicity and Fairness, and Best Execution. In my opinion, Payment for Order Flow (PFOF) and exchange rebates should be assessed together, as they both significantly influence order routing decisions. I contend that PFOF and exchange rebates should be prohibited due to their persistent issues, despite regulatory attempts to address them. PFOF is incompatible with the responsibility of best execution, as brokers who accept PFOF receive less price improvement. This adversely affects individual investors, as illustrated by Virtu Financial CEO Doug Cifu. I recommend banning PFOF and exchange rebates and shifting the focus towards execution quality. Both PFOF and exchange rebates negatively impact market quality by raising costs for investors, creating conflicts of interest, and reducing the likelihood of execution. Additionally, these practices result in increased market concentration by benefiting a select few trading firms. In conclusion, I commend the SEC's analysis of PFOF and its efforts to improve market conditions. However, I firmly believe that banning PFOF and exchange rebates is a necessary step towards ensuring a fair and transparent market that serves the best interests of all investors. Sincerely, Clifford Riggs San Jose, CA 95148