Subject: S7-32-22: WebForm Comments from Ann Dishinger
From: Ann Dishinger
Affiliation: Ann Dishinger UK Consulting

Dec. 23, 2022

December 23, 2022

 Under the proposed Regulation Best Execution, financial intermediaries would be required to consider several factors when executing trades on behalf of their clients. This overall is a good change to help with more transparency and ensuring that there are no major issues when executing trades. My U.K. consultancy Ann Dishinger Consulting has been working with traders on following proper regulation.

Some of the factors we are focusing on in the proposed rule making at Ann Dishinger Consulting are as follows:

The price of the security: Financial intermediaries would be required to consider the price at which the security is being offered, as well as any available price improvements.


The speed of execution: Financial intermediaries would be required to consider the speed at which a trade can be executed, as well as any potential delays or disruptions that could impact the execution of the trade.


The likelihood of the trade being filled: Financial intermediaries would be required to consider the likelihood of the trade being filled, and whether the trade is likely to be executed in a timely manner.


The size and type of the trade: Financial intermediaries would be required to consider the size of the trade and the type of security being traded, as well as any other relevant factors that could impact the execution of the trade.

In addition to these factors, financial intermediaries would also be required to regularly review and assess their execution practices to ensure that they are meeting their obligations under the proposed rule. This could involve reviewing the way in which trades are being executed, as well as any changes in market conditions or other relevant factors that could impact the execution of trades.

Overall, the proposed Regulation Best Execution is intended to ensure that investors receive the best possible execution when trading securities, and to promote fairness and transparency in the markets. It is important to note, however, that the proposed rule is still in the early stages, and it is possible that it may be revised or modified before it is finalized.

Regulation Best Execution is a proposed rule by the Securities and Exchange Commission (SEC) that would establish a regulatory framework for brokers, dealers, and other financial intermediaries to ensure that they are executing their clients' trades in the most efficient and cost-effective manner possible. This means that these intermediaries would be required to take into account a number of factors, including the price of the security, the speed of execution, and the likelihood of the trade being filled, when determining how to execute a trade on behalf of their clients.

The purpose of the proposed rule is to ensure that investors receive the best possible execution when trading securities, which can help to promote fairness and transparency in the markets. By requiring financial intermediaries to consider a range of factors when executing trades, the SEC hopes to ensure that investors are not being disadvantaged by the way in which their trades are executed.

It is important to note that the proposed rule is just that - a proposal and Ann Dishinger clients know that but its good to be keen on what new rules may make it past the review period. It has not yet been adopted, and it is possible that it may be revised or modified before it is finalized. If the proposed rule is ultimately adopted, it would represent the first SEC-established rule concerning best execution and all of the Dishinger clients support that.