Subject: S7-30-22: WebForm Comments from Dennis H
From: Dennis H
Affiliation:

Mar. 18, 2023

March 18, 2023

 Some companies run a \"price improvement scheme\". They say they give better trades than anyone else. And their numbers support that story. This gets them lots of order flow WITHOUT PFOF. What they can often do is get a better trade for household investors, but not the best trade. This enables them to steal order flow without actually giving a best price. I personally believe that they tweak price improvement to selectively apply it in some situations and not others, in a way that benefits them. These rules put legal requirements in place that should already be in place. They also force them to disclose more information about what they are doing to make sure they are acting in accordance with the rules.