Subject: S7-32-22: WebForm Comments from Stephen
From: Stephen
Affiliation: Consultant

Dec. 28, 2022

December 28, 2022

 Regarding rule 34-96496-

Dear Securities and Exchange Commission,

I am writing to express my support for the proposed Regulation Best Execution. I believe that establishing a best execution standard for broker-dealers and requiring them to maintain and enforce written policies and procedures to comply with this standard is essential to protect retail investors.

However, I also believe that the proposed regulation should go further in addressing practices that can harm retail investors. Specifically, I believe that payment for order flow (PFOF) and dark pools should be banned.

PFOF is a practice where a broker-dealer receives payment in exchange for routing a customer's order to a particular market for execution. This practice can create a conflict of interest for the broker-dealer, as they may be incentivized to route orders to markets that provide the highest payment for order flow rather than markets that offer the best execution quality for the customer.

Dark pools are private exchanges that allow traders to buy and sell securities without revealing their identities or the details of their trades. These exchanges can be used to manipulate securities by allowing large traders to execute trades without revealing their intentions to the market.

In addition, the recent failures to deliver (FTDs) in the market have been linked to PFOF, dark pools, and deep in/out of the money options. These failures can erode trust in the market and harm retail investors.

For these reasons, I believe that the proposed Regulation Best Execution should ban PFOF and dark pools to protect retail investors and promote fair and transparent markets.

Thank you for considering my comments.

Sincerely,
Stephen