Mar. 20, 2023
Dear Ms. Countryman, I hope this email finds you well. I am writing to discuss the importance of increasing transparency in the routing of orders by brokers and wholesalers, and the proposed changes to ATS rules that would promote better alignment with regulatory frameworks for exchanges. As an individual household investor, I support any initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of markets. To this end, the SEC should reduce conflicts of interest by increasing transparency in the routing of orders by brokers and wholesalers, with investors having access to the best priced quotations available in the NMS. We believe that ATS should submit detailed disclosures about their operations, including how they manage conflicts of interest, how they operate their order routing practices, and how they handle customer orders. This would make it easier for investors to understand how ATS operate and how their orders are executed, which is crucial for maintaining market transparency. According to recent studies, estimated savings for retail investors range from $1.12 billion to $2.35 billion, primarily through increased competition to supply liquidity to marketable orders. Competition in the marketplace is necessary to regulate markets better and barriers to competition, such as the conflicted nature of PFOF, should be removed. We urge the SEC to prioritize creating a competitive market structure that benefits investors and encourages transparency. This would not only benefit individual investors but also promote a healthier and more sustainable market for all participants. Thank you for your attention to these important issues. Sincerely, Dan V