Subject: File No. S7-31-22; Release No. 34-96495: Order Competition Rule
From: Tehmoi Richards
Affiliation:

Mar. 31, 2023

 

Hello I’m here to express my support for the aforementioned ruling. 


The rules proposed by the SEC and accompanying arms  of the govt. must have the teeth necessary to snap at the greedy hands of influential players who only seek to dominate the market through underhanded methods. This rule for order competition reform is a fine step.  


The retail investor who hears of Wall Street hedge funds and banks making billions from abusing us average people, get fined only a hundred thousand or just a million, understand we are an afterthought. It is time this changed, stronger punishments ranging from a major percentage of the stolen wealth and or loss of license to continue their practice. This money should be used to reimburse or reinvest in businesses and individuals that can trace their victimhood directly to the crime. 


With rules like this we can regain confidence, at home and abroad, in the integrity of our markets. Too long have a lagged behind in safeguarding our people from abuses of the rich. PFOF is a practice banned across out the markets of our ally’s, they have outpaced us in other fields as well. Without similar protections how can they trust in the strength and integrity of our markets when cracks in players of our hedge funds and banks are revealed? 


Ensure competition 


The elimination of the practices favoring the wholesaler should be dismantled immediately. The process that focuses on the auction of a share must be thorough before it reaches the hand of the wholesaler. The current practice allows broker, wholesaler, auction, and to wholesaler scenario for a share. A potential buyer should not  see a price before anyone else. Market advantages like this and dark pools allow for big players the advantage of knowing and setting prices beforehand, we the public should get that information at the same time. 


Lookin at 15 U.S.C. 78k-1 (“section 11A”) states that "It is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure ... fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets." . 
It is becoming increasingly obvious that this mission has failed. The off-exchange has reigned for too long. However, this an attempt to rectify the negligence we have experienced in the past. Thank you for working on a fix. 


A fix for the large swaths of shares being exchanged is desperately needed. Investigations by the SEC has yielded the truth that 90% of retail orders in NMS stocks are routed to six off exchange titans with two devouring 66% of trades. What is the point in investing in America in such a market? 
The question of “Does my trade, large or small, have any affect on the company I invest in?” , answers itself with a resounding “No”. To curb this fear, turned reality, we must simplify our markets and its adjacent structures around the accessibility for the common person. 


Wholesalers Are Not Trustworthy 


It has been the theme of my lifetime that when our economy is in peril we socialize the losses by bank rolling and bailing out the large institutions, to trickle down the surge of relief to retail. With Wells Fargo making fake accounts to pad their books and wallets https://www.forbes.com/sites/jackkelly/2020/02/24/wells-fargo-forced-to-pay-3-billion-for-the-banks-fake-account-scandal/?sh=3c0c7b9b42d2,  with JP Morgan finding ways to charge multiple overdraft fees https://www.propublica.org/article/jpmorgan-chase-bank-wrongly-charged-170-000-customers-overdraft-fees-federal-regulators-refused-to-penalize-it/amp , and Citadel hedge fund being found to violated regulations over 70 times (https://files.brokercheck.finra.org/firm/firm_116797.pdf), why should I trust them to play fair? Why should I trust them not to run the government when they take risky bets for bailouts? Why should I expect a major fundraiser for our markets and its players, Citadel, to have interests of the majority of the population in mind? Let’s take a more egalitarian approach for our markets and lessen the impact of back room deals that harm the average investor. We should not suffer with our orders being executed at less than favorable prices because of the influence of large money controlling the levers of our markets. Without dark pools and wholesales limiting our margins and cancelling our influence on the value of stocks, retail would see significant increases our trades value.  


I strongly urge the commission to pass this rule.