Subject: Comments on File No. S7-32-22; Release No. 34-96496· Regulation Best Execution
From: Lars Wohlfahrt
Affiliation:

Mar. 23, 2023

 


Dear Sir or Madame,

I am writing to express my strong support for File No. S7-32-22; Release
No. 34-96496· Regulation Best Execution. I believe that this proposal
will bring important improvements to the regulation of the securities
market, particularly in terms of investor protection and transparency.

One of my main concerns is that sending orders to a wholesaler for
internalisation should not be the only option available to investors.
This practice can lead to conflicts of interest and may not always
result in the best execution for the investor. Therefore, I strongly
support the proposal to increase transparency in the routing of orders
by brokers and wholesalers, with investors having access to the best
priced quotations available in the NMS.

I also believe that brokers may charge high commissions or fees in lieu
of Payment for Order Flow (PFOF), which can be detrimental to investors.
Therefore, I support the proposed cap on such fees to ensure that
investors are not unfairly burdened by excessive costs.

Furthermore, I commend the SEC for proposing changes to Alternative
Trading System (ATS) rules that promote better alignment with regulatory
frameworks for exchanges. This will be particularly beneficial for
individual household investors, who often lack the resources and
expertise to navigate complex market structures.

In conclusion, I strongly urge the SEC to adopt File No. S7-32-22;
Release No. 34-96496· Regulation Best Execution. These proposed changes
will improve the fairness and transparency of the securities market, and
ultimately enhance investor protection.

Thank you for your consideration.


Sincerely,

Lars Wohlfahrt