Mar. 31, 2023
To Whom it May Concern, Thank you for your time in reading and considering this letter- I am a household investor and small business owner. I believe that in order to build on the hard work I’ve invested in my business and my community - to have something to pass down to my children - and to invest in my own security for the future, that the financial markets must work fairly and in a way that ensures equal access and opportunities for all market participants. It has become clear through my observations of the markets over the past years that there are numerous ways in which large financial interests have continually gained numerous advantages, engineered or accessed legal loopholes, and created systems that inherently disadvantage household investors: the very people who makeup the moral and market fabric of our society are being exposed to a system that inherently works to extract the hard earned wealth that every day people are investing their lives into earning. It is with this thought in mind that I want to speak today in regards to order competition. A primary consideration in all rule proposals is that enforcement must exist, be firm, be effective, be swift, by consistent, and actually be a deterrent. It is my desire to significantly higher fines, that are highly dissuasive to those who may see the current fine structure as merely a cost of doing business. These costs must be debilitating and severe to any who are found to violate these practices. These costs should not be merely limited to punitive financial measures but should include significant professional consequences including the loss of licensure, loss of access to market segments, increased scrutiny or reporting requirements in the future or other measure to ensure that these rules have bite, and market participants are ready to ensure top to bottom organizational compliance with the regulations that end up in place. With that in mind I fully support the rule proposal here as far as market practicalities and desire its expedient implementation. Additionally any measures or efforts to reduce the harvesting of financial benefit through technical exploits like high frequency trading, internalization, or PFOF are greatly appreciated. Any efforts to reduce the abilities of financial firms to use financial, technical, or influential resources to unbalance the scales in their favor, are appreciated greatly. I believe that in a fair playing field - that is one with clear rules that all participants are aware of, one with clear penalties all participants are aware of, and engaged and fair referees continually monitoring the field for infractions - competition is one of the largest forces for the good of the most people. Conversely — a lack of transparency, or rules that effect one side more than another, or one side not at all, rules with numerous exceptions, or penalties that are minor inconveniences to the infracting party - these things are massively harmful to the integrity, and efficiency of our markets. One of the places we run into these malpractices are often in the world of wholesalers- which often keep trading as far from the fair “lit” markets as possible while internalizing them and taking orders off exchange as much as possible - to their benefit and participants detriment. These practices are anti competitive, monopolistic (especially considering some statistics showing that nearly over half of all marketable orders are routed through just two firms) and ineffective at moving the markets towards greater efficiency and transparency. This proposed rule is a good step towards reducing some of the issues noted in this letter and I urge you to consider further curtailing these problems. Thank you for your time- Alex Fleming