Mar. 31, 2023
Hello SEC, As a concerned and interested stockholder, shareholder, and investor in the United States equity markets, I want my support for this rule to be recorded. With this rule the SEC should reduce conflicts of interest by increasing transparency in the routing of orders by brokers and wholesalers, with investors having access to the best priced quotations available in the NMS. I support this rule because the proposed changes promote better alignment with regulatory frameworks for exchanges would be beneficial for individual household and retail investors. ATS (Alternative Trading Systems) should submit detailed and specific disclosures about their operations, including how they manage conflicts of interest, how they operate their order routing practices, and how they handle customer orders. This would make it easier for investors to understand how ATS operate and how their orders are executed. ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices. This change would help to protect individual investors from abusive practices in the ATS market. ATS should provide detailed information about the operation of their systems to the SEC, including data on the execution of orders, order routing practices, and information about the use of dark pools. This would improve the SEC's ability to oversee ATS and ensure compliance with regulatory requirements, with a strict and binding enforcement policy for violations. ATS implement a variable minimum pricing increment model for both quoting and trading of NMS stocks which would further promote fair and transparent pricing across trading venues, ultimately benefiting investors. I support initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. Sending orders to a wholesaler for internalization should not be the only option available to household and retail investors. If this rule is implemented brokers for household and retail investors may charge high commissions or fees in lieu of PFOF, so a cap should be implemented and enforced. Competition in the marketplace is necessary to regulate markets to become better and barriers to competition, such as the conflicted nature of PFOF, should be removed. The SEC should priorities creating a competitive market structure that benefits investors and encourages transparency. At the end of the day, enforcement of new and existing rules matters more than anything else. I expect to see higher fines, bigger penalties, and actual consequences for SEC violations. Resulting fines cannot be a relatively small cost of doing business for potentially abusive counterparties, the SEC must create and enforce fair markets by having all fines be larger than profits. With urgency and high expectations, Christopher McBride