Subject: S7-32-22: WebForm Comments from Stefan
From: Stefan
Affiliation:

Dec. 29, 2022

December 29, 2022

 dear Sirs,

As an individual investor, yet part of worldwide discussions with other engaged individual investors, I support this proposal.

May I ask your attention for two remarks?

First, rule 1100 'reasonable diligence' needs to be defined by SEC. Self regulating will lead to either conflicts over interpretations or gentlemen agreements among broker-dealers

Second, rule 1101(b) needs to be extended so far that 'internalization (trades not executed on open or lit markets)' by a broker-dealer is prohibited. For at the moment this leads to situations where buy orders are internalized for $25 not affecting fair market valuation for the bid side of the trade, but sell orders for $24.90 are thrown onto the open or lit market, hence affecting price so not reflecting fair value as the bid was $25. When a buy lot of 100 shares at $25 does not affect price, a 1 share sale of $24.90 does.

All retail orders should be directed to a lit market, unless a retail investor specifically demands a route to a specific exchange