Feb. 24, 2023
February 24, 2023 To the SEC Board, regulatory rule makers and investing market at large, Thank you for the chance to comment on this proposal as I see it as a positive change to the portions of order execution that are currently opaque and often manipulative of price discovery and the expected due diligence many household (retail end) investors expect of their brokers. Fed reg 34-96496 Rules 1100, 1101 (all parts), 1102 are endorsed by me to pass without amendment or any loophole provisions. I applaud making steps in a positive direction that not only increase trade transparency and strive for best execution and institute regular checks on compliance with meaningful repercussions for malfeasance or other market manipulation. My family, with myself as head of household, invests in real property, physical securities and investments, cash accounts, and equipment and hardware that holds tangible value that is widely known and understood and tradable on various markets. I also own digital securities which fluctuate in value, sometimes naturally due to fundamental market responses, but also all too often from manipulation tactics to pump and dump stocks or otherwise cage a stock price with illegal spoofing and technically legit high frequency trades that are aimed at coercing the options markets towards 'maximum pain' values. As a US citizen and household investor in public company shares, I expect that share value to also be tangible and deliverable based on the information provided to me by my brokers such as accurate Cost Basis and time of execution, and especially knowing that any retail order below what is considered a block trade still be traded on an open market and affect real price discovery. I'm unsure how the current system protects my investments from predatory market actions by self regulatory market makers and wholesalers. I expect protections as agreed under my brokerage accounts, but how am I to know when an internalized order certifies trades as \"executed\" but are occasionally later 'delivered' following a different transaction on the broker-dealer level? It matters because obfuscated trades affect price discovery and can allow for more powerful entities to short securities in tandem with other insiders, leaving retail trades artificially reduced in value. In My opinion, Best execution should mean the trade books are balanced at the time of execution, not at delivery. I'm acutely aware that actual cost basis when transferring to Direct Registration does not always match trade confirmation cost basis at the time of the execution between me and my broker. More importantly, how are agencies tasked with regulation to know how orders are executed or even what Best Execution means as a standard without rules such as 1100, et al? Brokers and wholesalers are netting benefits in opaque trades that are not transparent or verifiable beyond a digital IOU that gets lost in the complex market structure that is dominated by High Frequency Trades. Rule 1100 at least promotes the trades I make have a chance of being executed in lit markets like IEX or openly on the NYSE or NASDAQ. I would humbly implore that retail end investors also be given an option in future rulings for their concept of preferred best executions. This hypothetical rule would allow increased order competition by giving the retail investor the option of paying more fees to trade on exchanges like IEX or opt out of payment for order flow entirely. The best transparency is provided before the transaction no matter what is being exchanged. Many thanks for enacting due diligence and finally bringing much needed reforms to a market that I would really like to believe in. J Daniel San Diego