Subject: S7-32-22: WebForm Comments from John Smith
From: John Smith
Affiliation:

Mar. 30, 2023



 March 30, 2023

 The commission staff needs to provide an analysis summarizing how equity and options orders are handled by wholesalers, such as Citadel. Currently, these wholesalers do not provide detailed information related to order handling and payment for order flow arrangement in their 606 reports. For instance, in Citadel's most recent 606 filing (https://www.citadelsecurities.com/wp-content/uploads/sites/2/2023/01/SEC606a1_CSIN_Held_2022_Q4_20230123.pdf), Citadel routed 100% of the equity and options orders to an entity called CDRG. This does not make any sense. To further help the public understand the order handling practices of these wholesalers, the commission staff may use the regulatory data collected by the consolidated audit trail system.

The baseline subsection of section 5 does not provide sufficient information on how broker-dealers handle fixed income orders from retail clients. It would be helpful if the commission staff could provide additional analysis on this topic.