Subject: Comment Letter for File Number S7-31-22 Order Competition Rule
From: Guy Thomas
Affiliation:

Mar. 22, 2023

 


To whom it may concern. 


As a household investor, I find the current structure of the US equities markets to be horrifying and frankly corrupt. It beggars belief, and abhors those to whom I explain both the existence of, and prevalence of off-exchange trading. Off-exchange trading can barely be justified when discussing large block trades, but the fact that individual household and other small entity trades almost never make their way to the lit exchanges is shameful and a corrupt stain on the US markets. There is no justification for this, other than to control and/or suppress supply and demand. When a party is capable of deciding what to route to lit exchanges, and what to internalize, they get to front run investors, control supply and demand, and thus decide the price. Off-Market trading and internalization are simply methods of market manipulation, dressed up as a service. A service may I remind you, that we household investors never asked for, and still don't want. 


If you ask anyone from the street to explain how a fair and just stock market works, no one will talk about internalization, no one will talk about off-exchange trading. These are unnatural mechanisms for exploiting less powerful investors and nothing more.  There is no evidence for price improvement under the current structure of off-exchange trading, yet basic logic would suffice to identify the negative effect off-exchange trading has on supply and demand. 


Currently, off-exchange trading, FTD forgiveness and internalization destroy the basic principles of meaningful individual participation in the lit exchange required to ensure price discovery, supply and demand and a free market. For that reason I write this comment letter to support the notion of restricting off-exchange trading, and my full support of the trade-ad rule. 


I pose it to you Mr Gensler, to end PFOF, end excessive internalization and bring about the free market people one assumed existed. End this corruption, it's a stain on an otherwise great nation. 


Kind Regards 


Guy Thomas