Subject: S7-32-22: WebForm Comments from Matthew Gavyn Mutman
From: Matthew Gavyn Mutman
Affiliation: Universal Banker III

Mar. 07, 2023

March 7, 2023

 Dear SEC Commissioners,

As a retail investor, I am writing to express my full support for the proposal to regulate broker-dealers in upholding, executing, documenting, and proving best execution practices. I believe that this proposal is crucial for maintaining market stability, efficiency, and preventing market manipulation, as well as ensuring the security of retail investors.

Regarding the Commission's understanding of broker-dealers' current best execution practices, I agree that some broker-dealers currently incorporate various best execution factors from FINRA and MSRB rules in their policies and procedures. However, I think that it is essential for broker-dealers to incorporate all of the best execution factors from these rules to ensure that they are providing the best possible execution for their customers.

Additionally, I believe that broker-dealers should preserve information that allows them to support their best execution determinations, such as information to recreate the pricing information available at the time of an execution. This will help to ensure that broker-dealers can justify their execution decisions to their customers and regulatory bodies.

Regarding the Commission's understanding that broker-dealers' reviews of execution quality vary in rigor, I agree that there should be more consistency in how broker-dealers conduct execution quality reviews of customer orders. I believe that these reviews should be conducted rigorously and should be transparent to customers.

Finally, I agree that broker-dealers should periodically review their best execution policies and procedures. However, I believe that the frequency of these reviews should be standardized to ensure that they are conducted with the appropriate level of frequency to maintain the best execution practices.

In summary, I fully support the proposal to regulate broker-dealers in upholding, executing, documenting, and proving best execution practices. I believe that this proposal is essential for maintaining market stability, efficiency, and preventing market manipulation, as well as ensuring the security of retail investors.

Thank you for your attention to this matter.

Sincerely,

Matthew Gavyn Mutman