Subject: S7-32-22: WebForm Comments from Dennis H
From: Dennis H
Affiliation:

Mar. 18, 2023

 


  March 18, 2023

 Citadel and Virtu run a \"price improvement scheme\". They say they give the best trades, better than anyone else. And their numbers support that story. This gets them lots of order flow WITHOUT PFOF. What they can often do is get a better trade for retail, but not the best trade. This enables them to steal order flow without actually giving a best price. I have a suspicion that they mess around with price improvement to selectively apply it in some situations and not others, in a way that benefits them. These rules put legal requirements in place that should already be in place, and then force them to disclose more information about what they are doing to make it easier to tell when they're messing around.