Mar. 19, 2023
Dear SEC, I am writing to express my strong support for the proposed Order Auction Rule (File No. S7-32-22). This rule is an essential step towards promoting fairness, transparency, and competition in the US financial markets. Payment for Order Flow (PFOF) has already been banned in the UK due to conflicts of interest, and it is high time that the US follows suit. Studies have shown that brokers who do not accept PFOF consistently deliver superior execution quality. Additionally, a recent analysis revealed that retail investors not dealing with PFOF receive better prices, which is in direct violation of FINRA's Best Execution guidance. To further improve transparency, dark pools should be required to provide quotes and trades to consolidated market data. The SEC should also address the information advantage of wholesalers by mandating that brokers first route orders to the auction and specify where the order should go if the auction is unsuccessful. The current state of the American markets is anti-competitive, and it is crucial that the Commission works to ensure fair competition, particularly within the off-exchange systems that currently dominate. By removing middlemen from the market and implementing the proposed rule, individuals and institutions alike will benefit from improved prices and save billions of dollars. To maintain the integrity of the market, the SEC should thoroughly investigate conflicts of interest among market participants and improve the enforcement of its rules. This includes imposing higher fines as a deterrent and revoking licenses from broker-dealers who repeatedly violate regulations. In conclusion, I urge the SEC to implement the Order Auction Rule and take the necessary steps to promote transparency, fairness, and competition in the US financial markets. Thank you for your attention to this important matter. Sincerely, Robert Alexander Waelder from Gainesville Florida