Mar. 19, 2023
To whom it may concern, I am writing to express my support for increased transparency in the routing of orders by brokers and wholesalers. As an investor, I believe that it is important to have access to the best priced quotations available in the NMS. The proposed changes to ATS rules would promote better alignment with regulatory frameworks for exchanges and would be beneficial for individual household investors. To further improve transparency, I recommend that ATS submit detailed disclosures about their operations, including how they manage conflicts of interest, how they operate their order routing practices, and how they handle customer orders. It is also important for ATS to establish and enforce written policies and procedures to prevent fraudulent and manipulative practices. ATS should provide detailed information about the operation of their systems to the SEC, including data on the execution of orders, order routing practices, and information about the use of dark pools. To promote fair and transparent trading practices, ATS should operate in a manner that is consistent with the broader regulatory structure of the securities markets. Additionally, implementing a variable minimum pricing increment model for both quoting and trading of NMS stocks would further promote fair pricing across trading venues, which is essential for ensuring a level playing field for all investors. I support any initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. I believe that sending orders to a wholesaler for internalisation should not be the only option available to investors, and that a cap should be implemented on the commissions or fees charged by brokers in lieu of PFOF. Finally, I urge the SEC to prioritize creating a competitive market structure that benefits investors and encourages transparency. Estimates suggest that retail investors could save between $1.12 billion and $2.35 billion through increased competition to supply liquidity to marketable orders. Competition in the marketplace is necessary to regulate markets better, and barriers to competition, such as the conflicted nature of PFOF, should be removed. Thank you for your attention to these important matters. Sincerely, Eric C.