Mar. 23, 2023
Dear Sir or Madame, I am writing to express my strong support for Rule S7-31-22; Release No. 34-96495: Order Competition Rule. The proposed rule would improve competition in the securities markets and ultimately benefit investors by promoting fairer pricing, increased transparency, and greater innovation. The proposed rule would encourage competition by reducing barriers to entry and promoting market data transparency. This would enable smaller firms to compete on a more level playing field with larger incumbents, driving innovation and providing investors with better access to diverse products and services. I believe that increased competition will ultimately result in more efficient and resilient markets, better risk management, and more choice for investors. This is particularly important in the current environment, where technological advancements have made it easier for new firms to enter the market and challenge established players. Furthermore, the proposed rule is consistent with the SEC's broader mission to protect investors and promote fair, orderly, and efficient markets. By fostering competition, the SEC can help ensure that market participants are held to the highest standards of conduct and that investors are protected from abusive practices. The new rule to mandate a public auction for order placement instead of giving Citadel priority is important to ensure fair opportunity for all, including pension funds. Conflict-of-interest concerns have led to the effective ban of Payment for Order Flow (PFOF) in the UK, and the US market should follow suit. Brokers that avoid PFOF exhibit different routing behavior and generally provide better execution quality. Despite generating approximately 70% of Robinhood's revenue, a recent study found that PFOF does not result in statistically significant price improvement relative to exchanges. In summary, I fully support Rule S7-31-22; Release No. 34-96495: Order Competition Rule and urge the SEC to adopt it without delay. The proposed rule will promote competition and innovation in the securities markets, ultimately benefiting investors and strengthening the broader economy. Thank you for your attention to this important matter. Sincerely, Lars Wohlfahrt