Dec. 27, 2022
December 27, 2022 Hello again securities and exchange commission, its the intrepid individual retail investor here to comment on another one of your proposals again How exciting that must be for you guys, and of course as always I hope you find yourselves (and whoever to be reviewing this comment) having a wonderful morning/afternoon/evening This comment letter will be on the new proposal for Regulation Best execution, otherwise known as proposal File No. S7-32-22. To begin I would just like to say a rule establishing a best execution standard for brokers/dealers, government securities brokers/dealers, and municipal securities dealers from the SEC is fantastic, and I am in full support of this proposal. I would quite agree that promoting best execution of customers orders is of fundamental importance in our markets, and an excellent step towards a more transparent and free market. Proposed rule 1100 sounds pretty good on paper, but it would be great to see good enforcement on this rule. Gotta be careful with those exceptions though, you never know what kinda loopholes you might be leaving open with that, but still a fantastic start. Proposed rule 1101, including 1101(a) is great. Having broker dealers have written policies for best execution, and expecting them to enforce and maintain them is great for ensuring a more free, and transparent execution environment for retail orders. I would say having these only updated once a year is ok, but whats to say they shouldnt at the least be glanced at once a fiscal quarter? The markets can be quite fast paced and theres never any harm in making sure we all agree on what best execution means more than once a year. Proposed rule 1101(b), the rule for making sure broker-dealers with conflicting transactions is also fantastic. Reading this rule almost brings a tear to my eye as someone who hopes for free and transparent markets, in a good way I should say. Conflicts of interest run wild in the current markets, with retail investments being wholly judged behind the scenes by internalized routing. Commissioner Gary Gensler himself said 90-95% of all retail trades arent executed on exchange, and I can see this rule in particular helping increase transparency on those trades. Proposed rule 1101(c) for best execution review of transactions quarterly is also great, but it seems a little weird one would only look for best execution of trades quarterly in my eyes. With how many orders/transactions that could possibly be in our fast paced markets it would seemingly make much more sense to ensure quality best execution trades on a monthly basis at least. As for documenting the results of this review, thats great, especially if those documentation results are made available to the public so retail investors can have increased confidence in their orders and broker-dealers. Proposed rule 1101(d) and rule 1102 are great additions to what is overall an already stellar proposal from the SEC for retail investors. Just a bit more to help ensure best execution practices, and to help maintain the quality of the best execution ideals. As a quick add, that amend to require broker-dealers to preserve records? Fantastic. Its amazing to me in the digital age we live in the preserving of records isnt already something made standard in this industry. I cannot state enough how great it is to see a proposal like this being talked about by the SEC. As an individual retail investor, proposals like this go a long way to adding more of my confidence in the system.