Subject: S7-32-22: WebForm Comments from Jeremy Leach
From: Jeremy Leach
Affiliation:

Mar. 1, 2023

March 1, 2023

 I firmly support this proposed rule.

 If a wholesaler internalizes trades that it pays to have routed through itself and the exchange listed price is unaffected, how can a household investor participate in capital formation? How can a market be efficient when there is an invisible hand tipping the balance of supply and demand as it sees fit? The answer to both: They can't.

 A multi-million dollar-payment-for-order-flow industry has no place in an efficient market. Clearly this practice is beneficial if it justifies hundreds of millions being spent each year, but I'll eat my hat if it's beneficial to the household/retail investors.

 When up to 30% of retail orders executed each year are not routed to a lit exchange and reflected in the ticker price, we aren't seeing an efficient market, we're seeing a fleecing of household investors. Capital flows into to a handfull of firms and retail gets poor excecution quality, those same firms post record profits and people worldwide saving for retirment see little to no return on their investment.

The very fact that a line on a firm's financial statement reads \"securities sold, not purchased, $65 Billion\" is absurd, and straight up theft. It's a slap in the face to anyone who bought those securities and it's reflected in the rest of the market when that money doesn't go to a lit exchange.

The market in it's current state does not represent price discovery and therefor isn't a market, but a lottery. A lottery where a handfull of powerful firms have the winning numbers and can pick them at their leisure while pocketing hard-working peoples savings.

 This rule proposition is a solid first step towards efficiency, and REAL capital formation for household investors.