Subject: S7-31-22: WebForm Comments from Stefan
From: Stefan
Affiliation:

Dec. 29, 2022

December 29, 2022

 dear Sirs,

As an individual investor, engaged in discussions worldwide with other retail investors, I support this proposal.

May I ask your attention for one remark?

The $1.5billion competitive shortfall as you mention is probably a large part of the payment for order flow PFOF 'costs' mentioned in the hearings in 2021 by the two largest parties executing retail orders. Those orders are mostly internalized.
This means that 'no-cost' orders as marketed to retail by those parties do not exist in reality. Someone has to cough up those costs. Retail does of course.

You found an elegant way to not prohibit PFOF, yet make it less profitable therefore hopefully better for retail orders.
Props