Subject: RE: File No. S7-32-22; Release No. 34-96496· Regulation Best Execution
From: Simon Leprince
Affiliation:

Mar. 21, 2023

  


Hello, I am a canadian investor interested in the american market. I contact you today about comments I have about a new rule (in the subject): 


The proposed changes to Alternative Trading Systems rules promote better alignment with regulatory frameworks for exchanges would be beneficial for individual household investors. 


ATS should 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. This would make it easier for investors to understand how they operate and how their orders are executed. 


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. This would improve the SEC's ability to oversee ATS and ensure compliance with regulatory requirements. 



ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices. This would help to protect individual investors from abusive practices in the ATS market. 


ATS should operate in a manner that is consistent with the broader regulatory structure of the securities markets, which would benefit individual investors by promoting fair and transparent trading practices. These practices need to be stated in clear, unambiguous language. 



ATS implement a variable minimum pricing increment model for both quoting and trading of NMS stocks which would further promote fair and transparent pricing across trading venues, ultimately benefiting investors. 


The proposal to implement a variable minimum pricing increment model for both quoting and trading of NMS stocks would promote fair pricing across trading venues, which is essential for ensuring a level playing field for all investors. 


Household investors support any initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. 
Sending orders to a wholesaler for internalisation should not be the only option available to investors. 


Brokers may charge high commissions or fees in lieu of PFOF, so a cap should be implemented. 


Competition in the marketplace is necessary to regulate markets better and barriers to competition, such as the conflicted nature of PFOF, should be removed. 


The SEC should prioritise creating a competitive market structure that benefits investors and encourages transparency. 



An opaque market means the market is not free nor fair.   



Thank you for reading my comments. 
Have a good day. -- 


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