Mar. 31, 2023
Good day, I fully support any SEC efforts to reduce conflicts of interests and increasing transparancies in order routing between lit market, ATS and "dark pools" operated and maintained by broker-dealers, clearing houses and whole-salers to that they are obligated by law to offer best price execution and price discovery along all market participants who do not own or operate these kind of trading systems and are subject to the same compliance issues that are not set in law along with household, retail and institutional orders. These changes and enforcement would increase transparancy and price discovery through through the entire stock market and this rule would complement the SEC enforcement framework to make the United States stock market more fair, transparant and most importantly honest. These propesed changes would not only benefit United States household, retail and institutional orders, but also from any where in the world as these are also routed through broker-dealers, whole-sales and internalizations. ATS (Alternative Trading Systems (ATS are SEC-regulated electronic trading platforms that match buyers and sellers of stocks) 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. ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices. This would help to protect individual investors from abusive practices in the ATS market. ATS should provide detailed information about the operation of their systems to the SEC, including data on the execution of orders, order routing practices, and information about the use of dark pools. This would improve the SEC's ability to oversee ATS and ensure compliance with regulatory requirements. ATS should operate in a manner that is consistent with the broader regulatory structure of the securities markets, which would benefit individual investors by promoting fair and transparent trading practices. ATS implement a variable minimum pricing increment model for both quoting and trading of NMS stocks which would further promote fair and transparent pricing across trading venues, ultimately benefiting investors to compliment rule 34-96494. The proposal to implement a variable minimum pricing increment model for both quoting and trading of NMS stocks would promote fair pricing across trading venues, which is essential for ensuring a level playing field for all investors across the globe. Brokers should be capped on transaction fees in lieu of PFOF fees, in europe this is already implemented with a minimum transaction fee percentage capped to a maximum fee they can charge for an transaction that exceeds the cap with transaction percentage. Please consult Dutch regulators as we have these rules in place for maximum transaction fees that brokers can charge per order. It is clear to me how removing the profiteering middlemen from the market will improve prices for both individuals and institutions (e.g. pension funds). Recent research by Hittal Mittesh suggests that on top of the Commission's estimate that the auctions would save individuals from billions of dollars taken by wholesalers, it would also save institutions over $1.5 billion each year. Wholesalers are taking from citizens AND people's pensions - that needs to stop. Citation: https://4982966.fs1.hubspotusercontent-na1.net/hubfs/4982966/BestEx%20Research%20Order%20Competition%20Rule%20Analysis%2020230105.pdf Competition in the marketplace is necessary to regulate markets better and barriers to competition, such as the conflicted nature of PFOF, should be removed. Sending orders to a wholesaler for internalisation should not be the only option available to investors. Household investors will always support the SEC to implement any rules that enforces all market participants to trade in a fair, transparant and honest way to promote competition for true price discovery and no unfair disadvantages to honest participants which include household, retail and institutional participants. The SEC should prioritise creating a competitive market structure that benefits investors and encourages transparency. Please give household investors a voice for the first time in history! Best regards, Nimrod Fogel