Mar. 31, 2023
Dear SEC, I am writing to express my strong support for the Order Competition Rule, File No. S7-31-22, Release No.34-96495, which seeks to improve competition and transparency in the securities markets. As an avid investor, I believe that fair competition is crucial to protecting investors and maintaining a level playing field for all market participants. It is important to note that every rule the SEC passes is only as effective as the enforcement that backs it. I firmly believe that higher fines that serve as a significant deterrent should be implemented for rule-breakers, including the possibility of license revocation for broker-dealers who engage in misconduct. This will help to ensure that ill-gotten gains obtained through "honest mistakes" do not outweigh the cost of doing business. The current state of the American markets is clearly anti-competitive, and monopolistic behavior must be addressed. The proposed Order Competition Rule is an important step in that direction. As stated in 15 U.S.C. 78k-1, fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets is essential for protecting investors and maintaining fair and orderly markets. The current market structure is overly complicated, which benefits large, dominant players. I prefer a more simple, transparent, and free market structure like the one proposed in this rule. I deeply appreciate and support any efforts to reduce the speed games that damage the integrity, credibility, and functioning of American markets. I also support any efforts to reduce inducements and to reduce the 'farming' of individuals' orders for rebate money. The proposed rule's provision to address the unfair information advantage that wholesaler intermediaries have over other market participants is especially welcome. Furthermore, I strongly believe that wholesaler intermediaries are detrimental to the market and should be eliminated. Wholesalers have conflicts of interest and a long record of flouting the law. The Commission's analysis of CAT data demonstrates that wholesalers are executing shares of individual investor marketable orders at prices less favorable than the NBBO midpoint, which costs individuals and institutions billions of dollars. Removing these profiteering middlemen from the market will improve prices for both individuals and institutions, such as pension funds. In conclusion, I fully support the proposed Order Competition Rule, and I urge the SEC to implement it as soon as possible. Thank you for your attention to this important matter. Sincerely, Jack Vanstone