Subject: S7-31-22: WebForm Comments from Adam Gagnon
From: Adam Gagnon
Affiliation: IT Professional

Mar. 22, 2023



March 22, 2023

 To Whom It May Concern,

I am writing to express my strong support in FAVOR of the S7-31-22 Order Competition Rule.

I agree with this rule as proposed, its major tenets being:  \"promote competition\", \"restrict and prevent internal execution of orders\", and additionally, I support all minor related rule changes listed in S7-31-22 that help to explain, define terms, or aid these changes.

Internalization of retail or household orders should be disallowed.  Competition around those orders should be allowed to improve.  These ideas should be enacted and enforced, with the mission statement from the SEC in mind:  To protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation.

When many of us entered the market, it was our understanding that buying and selling pressure were the inalienable market forces that drove the demand and asking price for an equity.  That price would be established through a reasonable discovery process:  Investors buying would increase the price, investors selling would decrease the price.  Internalization represents the opposite, moving buyers away from willing sellers, and into the net of intermediaries who would supplant a fair auction process and price discovery.

The rules currently allow \"preferred treatment\" and \"discriminatory treatment\", based on status and origin of a market participant and order.  To force a purchase in one market (where the public asking price is ignored), and then to buy in another, private market, (where the price is allowed to be competitive) are anti-competitive acts by the market and makers.

Beyond simple reason and logic - the market players that abuse the current rule structure are literally cutting pennies out of every trade and pretending that it represents \"best execution\".  Allow all market participants on to the LIT and COMPETITIVE market