Apr. 01, 2023
Dear Sir/Madam, I am writing to express my support for the proposed Order Competition Rule, File No. S7-31-22, Release No.34-96495. I strongly believe that fair competition is important for the integrity, credibility, and functioning of American markets, and this proposed rule is an important step in that direction. I appreciate the efforts of the SEC to reduce the speed games that damage the markets, reduce inducements, and increase transparency. I fully support the proposed rule and urge you to implement it as soon as possible. I am particularly pleased to see the proposed rule address the issue of wholesalers and their unfair information advantage, which gives them a clear monopolistic position in the marketplace. I would like to see higher fines that serve as a significant deterrent and the revocation of licenses for some broker-dealers instead of just imposing fines that amount to nothing more than a cost of doing business. It is time to end the dominance of off-exchange systems and bring more transparency to dark markets. The investing public should have easy access to what is happening within the markets. Wholesalers exercise extreme influence on other market participants, and I am concerned that this influence will infect the ability of some participants to objectively review these rules. It is evident that wholesalers have clear conflicts of interest, and I would prefer to pay more per share or commission to avoid being routed through a wholesaler with a long record of flouting the law. Removing profiteering middlemen from the market will improve prices for both individuals and institutions, such as pension funds. Recent research suggests that on top of the Commission's estimate that the cost of the current market structure is around $5 billion per year, there is an additional $1.3 billion cost imposed by wholesalers. If these middlemen were not around to take their cut, the savings would go to citizens and pensions instead of into Wall Street's pockets. In conclusion, I strongly support the Order Competition Rule and appreciate the SEC's efforts to promote fair competition in American markets. Thank you for your attention to this matter. Sincerely, Luis J. Gomez