Mar. 31, 2023
March 31, 2023 I strongly support the proposed rule. It is well documented that an increasing number of equity orders are executed in dark pools by off-exchange market makers (\"off-exchange MMs\"). Precisely because darks pools enjoy less SEC oversight and therefore more flexibility than lit exchanges. Within these dark pools, off-exchange MMS have the ability to obscure price discovery, engage in front running, as well as prevent fair competition by waiting until market close to execute orders. These advantages enjoyed by the few have come at the expense of individual investors. Particularly as payment for order flow has concentrated retail investor orders in the hands of a very small number of off-exchange MMs. Tick harmonization across trading venues will eliminate some of the unfair advantages enjoyed by off-exchange MMs thereby eliminating some motivation to execute orders in dark pools rather than the lit-exchanges. The SEC should go further, however, and eliminate PFOF. By now everyone knows that commission free trading is not free. Retail pays the hidden cost in higher prices when they buy and lower prices when they sell. Personally, I would rather pay the commission, know the cost up front for the trade, and have some reason to believe I will get best execution. Additionally, the SEC should restrict the use of dark pools to the sole purpose for which they were created. The facilitation of block trades by institutions without adverse impacts on price. Rather than create price stabilization it appears dark pools are tools for price manipulation.