Mar. 12, 2023
Order Competition Rule S7-31-22 Investors should have access to the best priced quotations available in the national market system and such prices generally should be determined by competitive market forces. In plain words, I want to pay commission for my trades if that means achieving the best price and allowing for price discovery in markets. It shouldn’t be possible to wholesale orders from individuals to institutions. This is quite literally the opposite of supply and demand which our entire markets are built on. Citadel recommended withdrawing this proposal for a number of reasons, including the unprecedented nature of requiring certain market participants to utilize a specific trading protocol. Sending my orders to a wholesaler to be internalized is a specific trading protocol that I’d rather pay commission to be able to avoid. A wholesaler such as Citadel who has been front-running customer orders since 2006 shouldn’t have a monopoly on retail order flow. My only concern is that brokers will start charging outrageous commissions or fees in lieu of PFOF, so I’d recommend a cap on the amount of commissions or fees that the brokers are allowed to charge. I trust the Economic Analysis done by the commission and I look forward to retail saving costs. The SEC Historical Society has a Youtube video titled Regulation and Market Structure from ATS to NMS published June 1 2018. At 35:09, Dr. Richard R. Lindsey, division director from 1995 - 1998 states “Really what you wanted was competition in the marketplace. And that competition really regulated markets much better than the SEC could. We didn’t view it as our job to design the market, we viewed it as our job to try to allow more competition to exist.. To let competition exist you actually have to remove the barriers to competition that exist”. I agree with this. One barrier to competition is the conflicted nature of PFOF. Thank you, John Skrainka -- Data Engineer