Mar. 29, 2023
March 29, 2023 I have been a regulator (SEC and FINRA), an attorney representing the industry, a compliance officer and in house counsel. I have dealt with best execution in all those roles. I simply point out that the data as to which venue is best is rarely unambiguous. While a venue may excel in price improvement, it may lag in E/Q, speed of execution or ability to handle all types of orders. Broker-dealers may want to use multiple venues for business continuity. Proposed Regulation Best Execution is not needed and does not seem to recognize the nuanced decisions broker-dealers face in selecting venues. I respectfully urge the Commission to not adopt Regulation Best Execution. My comments are my own, and do not reflect current or former employers.