Mar. 19, 2023
Dear SEC, I am writing to express my support for the proposed Regulation Best Execution and urge you to implement the changes suggested in the rule. As an investor, I believe that reducing conflicts of interest and promoting transparency in the routing of orders is crucial for ensuring fair and efficient markets. I believe that the proposed changes to ATS rules will benefit individual investors by promoting better alignment with regulatory frameworks for exchanges. It is also important that ATS submit detailed disclosures about its operations to make it easier for investors to understand how they operate and how their orders are executed. This will help prevent fraudulent and manipulative practices and ensure that investors are protected from abusive practices in the ATS market. I also support the proposal to implement a variable minimum pricing increment model for both quoting and trading of NMS stocks. This would promote fair pricing across trading venues and help ensure a level playing field for all investors. Competition in the marketplace is necessary to regulate markets better and barriers to competition, such as the conflicted nature of PFOF, should be removed. It is also important to note that brokers may charge high commissions or fees instead of PFOF, and a cap should be implemented to ensure that investors are not negatively impacted. I urge the SEC to prioritize creating a competitive market structure that benefits investors and encourages transparency. By doing so, we can identify and prevent fraudulent practices that undermine the credibility, integrity, and functionality of American markets. Estimated savings for retail investors range from $1.12 billion to $2.35 billion, primarily through increased competition to supply liquidity to marketable orders. I believe that implementing these changes would be a significant step forward in creating a fair and efficient market that benefits all investors. Finally, enforcement is the last piece of the puzzle. If this rule were to go through, alongside every positive rule the SEC has put up for comment recently, then enforcement is needed to make sure the rules are followed. Enforcement could be markedly higher fines or revoking certain market-making or broker privileges. This is a country of law, and there must be consequences for breaking it. Thank you for your consideration of my comments. Sincerely, Hussain Shahabuddin