Mar. 26, 2023
Dear SEC, I am writing to draw your attention to some important points regarding the current state of American markets. The current situation is anti-competitive and has serious implications for individual and institutional investors. To ensure fair competition, the Commission needs to take action to implement several changes. Firstly, support for the new rule is necessary, which requires that Citadel cannot be the first to receive orders. Instead, orders must go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order. Secondly, Payment for Order Flow (PFOF) should be banned in the US markets, as it has been in the UK, due to conflict-of-interest concerns. Brokers who do not accept any kind of PFOF route orders differently and consequently see superior execution quality than those dealing with PFOF. Thirdly, it is important to note that retail investors not dealing with PFOF get a better price than those dealing with it, violating FINRA's Best Execution guidance. Therefore, FINRA is evaluating the impact of not charging commissions on member firms' order-routing practices and decisions, and the findings should be made public. Moreover, removing middlemen from the market will improve prices for both individuals and institutions, such as pension funds. The auctions will save individuals billions of dollars taken by wholesalers. It is also crucial to ensure fair competition by reducing monopolistic behavior and removing profiteering middlemen from the market. Dark pools (Alternative Trading Systems) should provide quotes and trades to consolidated market data to bring more transparency to dark markets. The SEC should investigate conflicts of interest among market participants to ensure that participants can objectively review the rules. Enforcement of SEC rules needs to be improved with higher fines to serve as a significant deterrent for breaking the law. Some broker-dealers should lose their licenses instead of receiving fines that amount to a cost of doing business. I urge the Commission to take swift action to ensure fair competition and transparency in the market. Sincerely, Joshua Cyr