Subject: S7-32-22: WebForm Comments from Richard Wallace
From: Richard Wallace
Affiliation: Attorney

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.