Mar. 22, 2023
To those in the SEC responsible, I am a household investor who worked a brokerage in the early 2000s for a period of approximately 6 years. Since that time, Payment for Order Flow (PFOF) became more and more popular in tandem with a rise of the “retail investor” and many of the brokerages that hope to capture the “retail investor” market. I watched this unfold as I invested primarily long term in solid companies that were affected by macroeconomic black swan events. In many cases, these companies, their investors, and their employees and their families, were adversely effected by events outside of their control. While some of these events were beyond influence of policy, others sadly were. PFOF policy is critical in this regard. The influence that PFOF on the markets today has ultimately been detrimental to price discovery, has unnecessarily created conflicts of interest between brokerages and market makers, and in the guise of creating best price of execution for “retail investors” has ultimately enabled a transaction skimming vehicle by market makers that can become a vehicle (especially when combined with special market maker privileges) to manipulate the price discovery of individual securities. And because it can be used for that, it is safe to assume—given the history of financial investors—that it is being used to that end and will continue to be. It is for this reason that I firmly oppose PFOF, and believe it should be outright banned in the US, as it has been in many countries around the world. Thank you, Joshua Forester