Subject: Regulation Best Execution; File No. S7-32-22
From: Matt Waterman
Affiliation:

Mar. 26, 2023

  


Brokers generally act as agents for their customers and, although not specifically defined, owe them a duty of Best Execution, which is derived from common law agency principles and fiduciary obligations.
 
FINRA has a best execution rule, but it’s about time it becomes a rule that the SEC can enforce. I support the Best Execution rule, but I don’t see how “conflicted orders” belong in a Best Execution rule. If payment for order flow continues, these “conflicted” brokers will continue to send our orders anywhere that gets them the most profit.
 
PFOF has been effectively banned in the United Kingdom due to conflict-of-interest concerns, and I’d like to see the same policy implemented here. I generally support this proposal for best execution but am concerned about these conflicts of interest that broker dealers may have with their clients. Thank you for consideration.
 
Matt Waterman,