Subject: Re: Order Competition Rule, File No. S7-31-22, Release No.34-96495
From: Tim Rines
Affiliation:

Mar. 13, 2023

 




The effectiveness of SEC rules depends on their enforcement, and I advocate for higher fines that serve as a real deterrent. In some cases, broker-dealers should lose their licenses instead of paying fines that are just a cost of doing business. I fully support the new rule and urge its prompt implementation. 
I strongly support any measures to curb harmful speed games and reduce inducements and "farming" of individuals' orders for rebate money in American markets. 
The practice of routing orders through wholesalers and auctions grants the wholesalers an unfair information advantage, and I urge the Commission to address this by requiring brokers to first route orders to the auction and specify an alternate route if the auction is unsuccessful. 




I appreciate and support recent rule changes that increase transparency in dark pools, such as requiring them to provide quotes and trades to consolidated market data if they operate as an auction. Easy access to market information is important for investors.The evidence indicates that wholesalers are extracting billions of dollars from individuals and institutions under the guise of "superior performance". Although they may manipulate their data to safeguard their profits, we are aware of their tactics. If wholesalers were not present to receive their share, the savings would be channeled towards citizens and pensions instead of boosting the already well-stuffed wallets of Wall Street. 



Tim