Mar. 18, 2023
I am in favor of the entitled rule, as it would both permit the SEC to act in concordance with its regulatory duty and to ensure the transparency of our market system. Specifically, this rule would enable the SEC to enforce fair competition per 15 U.S. Code § 78k–1 subsection (C), sub-subsection (iii). The current system of best execution permits larger firms to preferentially fulfill orders, if that fulfillment corresponds with the regulations surrounding order execution. Larger firms, while providing liquidity, are able to allocate asks to bids within their own private markets. This allocation of asks within private markets (dark pools) inhibits price discovery, and prevents fair competition. The Order Competition Rule would first direct trades to the open market, which would increase competition and enhance the US Stock Market's international reputation. Additionally, I am against "wholesalers" who act to consolidate market activity for their own benefit. Firms like Citadel securities are able to bundle transactions, and use those bundled transactions to save costs for investors. However, this cost savings comes at the cost of competition. The actions of wholesalers create added complexity, and provide significant, additional costs to our markets. Best Regards, Louis Moncure