Feb. 24, 2023
February 24, 2023 Dear SEC Commissioner, I am writing to express my opposition to the proposed Regulation Best Execution. As a retail investor, I believe that the best execution standard is nothing but a way for brokers, dealers, and other market participants to enrich themselves at the expense of small investors like myself. Firstly, I take issue with the fact that this proposal would require broker-dealers to establish, maintain, and enforce written policies and procedures reasonably designed to comply with the best execution standard. This would increase the regulatory burden on broker-dealers, which would ultimately be passed on to investors in the form of higher fees and commissions. Moreover, I believe that the proposed best execution standard would do little to protect investors. While it is true that the duty of best execution requires broker-dealers to execute customers' trades at the most favorable terms reasonably available under the circumstances, I fear that this standard would be difficult to enforce and would provide little protection to retail investors. In my view, the best execution rule would only serve to benefit large institutional investors and other market participants. These players have the resources and expertise to navigate complex markets and obtain the best possible execution for their trades. Retail investors, on the other hand, do not have access to the same resources and are therefore at a significant disadvantage. I also take issue with the fact that the proposed rule would exempt broker-dealers that qualify as \"introducing brokers\" from certain requirements if they establish, maintain, and enforce specified policies and procedures. This would create an uneven playing field, with some broker-dealers subject to more stringent requirements than others. Additionally, I am concerned that the proposed rule would require broker-dealers to review the execution quality of their customer transactions at least quarterly. This would further increase the regulatory burden on broker-dealers and could result in higher fees and commissions for investors. Finally, I am opposed to the proposal to amend Exchange Act Rule 17a-4 to require broker-dealers to preserve records made pursuant to proposed Regulation Best Execution. This would further increase the regulatory burden on broker-dealers, which would ultimately be passed on to investors in the form of higher fees and commissions. In conclusion, I believe that the proposed Regulation Best Execution would do little to protect retail investors and would only serve to benefit large institutional investors and other market participants. As a retail investor, I urge you to reconsider this proposal and to focus on policies that will truly protect small investors like myself. The entire practice of payment for order flow must come to an end to ensure an equal and fair trading environment. Sincerely, Jacob Gillmore