Jan. 12, 2023
January 12, 2023 Although I like the concept of this rule, I think the problems to be addressed could also be helped with banning so-called PFOF (Payment for Order Flow) outright. The current market system, being based on rebates and high-speed trades, incentivizes volume over execution. The fact that retail investors ever actually receive the securities they buy is secondary in a PFOF-driven marketplace. Even still, large wholesalers make a lot of their revenue on so-called \"price improvement\" by front-running their own client orders, and the order competition rule would at least make such a thing marginally harder for them to this. However, the 100-300msec time duration specified, as well as the ability for wholesalers to continue to \"internalize\" these orders with T+3 settlement times seems to make this rule change more of a gesture of good will, rather than an effective policy. Maybe just ban wholesalers outright, and somehow incentivize lit markets to take retail odd-lots and segmented orders go right to the the lit exchanges, as other orders to. The entire concept of \"wholesalers\" existing in the modern computerized era of trading is insane, when most retail market participants are within 100msec round-trip pings to lit market exchange computers. Again, though, I appreciate the SEC at least trying to help retail and individual investors out. I'm still DRSing everything, though, and using the Direct Registration System for all future orders for my long-term investment holdings.