Mar. 22, 2023
Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 205499–1090 rule-comments@sec.gov Re: Rule Proposal No. 34-96496; File No. S7-32-22 Regulation Best Execution and Rule Proposal No. 34-96494; File No. S7-30-22 Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders Ms. Countryman: I have chosen to use this letter to explain my beliefs as a household investor. While I might lack the citations and wording of what I think is wrong about the current system we are engaged in, the following best reflects my principals and what I see as an opportunity to make our current financial system a better one. Payment for order flow simply put, negatively impacts my right to obtain a best price for the securities I purchase. By routing purchases to wholesalers, who in turn, front-run trades, take profits and internalize orders, in no way benefits me as a household investor. In fact, it does just the opposite. True price discovery cannot happen under such a system, and because of firms such as Citadel, Virtu, and others, who engage in PFOF as a tenet of their business model as well as hugely profit from it, it severely undermines transparency, trust, fairness and the judiciary responsibility to the household investor within the financial system. Our free market survives and thrives under the auspices of healthy competitive practices, not from the machinations of corporate financial monopolies. Firms such as Citadel and Virtu, may not negotiate the terms of order routing for household investors in such a way that it reduces the price improvement opportunities that would otherwise be available to those same customer orders absent payment for order flow. To do so, is a clear violation of FINRA’s best execution guidance. I would ask that the practice of payment for order flow be stopped, as the time has come for greater market transparency for all. Sincerely, A concerned household investor