Mar. 31, 2023
Dear SEC, I am writing to express my support for the proposed changes to Alternative Trading Systems (ATS) rules and to suggest additional measures to increase transparency and protect investors. Firstly, I strongly believe that conflicts of interest can be reduced by increasing transparency in the routing of orders by brokers and wholesalers. Investors should have access to the best-priced quotations available in the NMS. To achieve this, ATS should submit detailed 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. Additionally, ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices, which would protect individual investors from abusive practices in the ATS market. Furthermore, 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. ATS should also operate in a manner that is consistent with the broader regulatory structure of the securities markets, which would benefit individual investors by promoting fair and transparent trading practices. I am also in support of the proposal to implement a variable minimum pricing increment model for both quoting and trading of NMS stocks. This would promote fair pricing across trading venues, which is essential for ensuring a level playing field for all investors. Household investors support any 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 investors. Brokers may charge high commissions or fees in lieu of PFOF, so a cap should be implemented. Competition in the marketplace is necessary to regulate markets better and barriers to competition, such as the conflicted nature of PFOF, should be removed. Estimated savings for retail investors range from $1.12 billion to $2.35 billion, primarily through increased competition to supply liquidity to marketable orders. In conclusion, I urge the SEC to prioritize creating a competitive market structure that benefits investors and encourages transparency. These measures would increase confidence and trust in the market and protect individual investors from abusive practices. Thank you for your consideration. Please do the right thing by ordinary working Americans. Please. Sincerely, -James Garland