Subject: RE: File No. S7-32-22; Release No. 34-96496. Regulation Best Execution
From: Jordan Manntz
Affiliation:

Mar. 31, 2023

 


I support this rule change.
 
The SEC should focus on reducing conflicts of interest and increasing transparency in the routing of orders by brokers and wholesalers. By providing investors with access to the best-priced quotations available, we can promote fair and transparent trading practices.
 
The proposed changes to ATS rules would also be beneficial for individual household investors. It's important that ATS submit detailed disclosures about their operations, including how they manage conflicts of interest and handle customer orders. This would help investors understand how ATS operate and how their orders are executed. We should also establish and enforce policies to prevent fraudulent and manipulative practices in the ATS market. This would protect individual investors from abusive practices and improve the SEC's ability to oversee ATS compliance.
 
It's essential that ATS operate in a manner consistent with the broader regulatory structure of the securities markets, ultimately promoting a level playing field for all investors. Additionally, implementing a variable minimum pricing increment model would promote fair pricing across trading venues.
 
Of course, we can't forget about the importance of competition in regulating markets. That's why we need to remove barriers to competition, such as the conflicted nature of PFOF. And while sending orders to a wholesaler for internalization shouldn't be the only option available to investors, a cap on high commissions or fees may be necessary.
 
Ultimately, creating a competitive market structure that benefits investors and encourages transparency should be a top priority for the SEC. After all, we're all in this game together, and we all deserve a fair shot.
 
Sincerely,
 
Jordan Manntz
A Fair Market Activist