Mar. 19, 2023
Hello Ms. Countryman, I am writing in support of the proposed Regulation Best Execution rule. For the market to function efficiently and fairly orders should be available to all participants to fill at the best price, not routed to a single participant. PFOF is antithetical to free market principals and it should be obvious why it has been banned in Europe and elsewhere. PFOF is anticompetitive at its core and even if it does improve price for household orders, which it is not clear that it does, I would gladly pay a premium to be able to participate in the broad market rather than being funneled into a PFOF scheme. I do not understand how wholesalers can provide price improvement on both sides of the trade while at the same time extracting billions from the market. It just doesn't add up. Markets function best when transparency is optimized and unnecessary intermediaries are minimized. Offenders should be fined such that it is not profitable to break the rules and repeat offenders should lose their license. This proposed rule would help to reduce anticompetitive practices and restore confidence in the market. As things exist now with PFOF, dark pools, and market makers running their own hedge funds, transparency and meaningful enforcement to restore some semblance of a free and fair market are desperately needed. Thank you, Lee Cunningham