Subject: S7-32-22: WebForm Comments from Peter Unum
From: Peter Unum
Affiliation:

Mar. 19, 2023



March 19, 2023

 The proposed SEC rule to ensure fair competition in the American markets is a step in the right direction. It is essential to prioritize true competition as the current state of the markets is anti-competitive, and monopolistic behavior is prevalent. The Commission needs to take steps to reduce this behavior and enforce fair competition, especially within the off-exchange systems that dominate the market.

Higher fines that serve as significant deterrents are necessary for the enforcement of SEC rules. Some broker-dealers should lose their licenses instead of receiving fines that only amount to the cost of doing business. The fragmentation of the market only benefits large, dominant players, and a simpler, more transparent, and free market structure is preferable.

Wholesalers exercise extreme influence on other market participants, and there are clear conflicts of interest that may infect the ability of some participants to objectively review the rules. Wholesalers are taking billions from individuals and institutions and calling it \"superior performance\" while lying about the quality of their services to maintain their profits. Removing middlemen from the market will improve prices for both individuals and institutions, such as pension funds.

It is important to address unfair information advantages granted to wholesalers by having brokers first route orders to the auction and specifying where the order should go if the auction is unsuccessful. The proposed rule to bring more transparency to dark markets should be implemented as soon as possible. The investing public should have easy access to what is happening within the markets.

In conclusion, the SEC needs to ensure fair competition, reduce monopolistic behavior, and remove profiteering middlemen from the market. The proposed rule to ensure fair competition is essential, and it is imperative to implement it as soon as possible. The current state of the markets is not fair, and true competition is necessary.