Mar. 31, 2023
Dear SEC Members, I am writing to express my strong support for the proposed changes to Alternative Trading Systems (ATS) rules and my recommendations to further promote fair and transparent trading practices. First and foremost, I urge the SEC to reduce conflicts of interest by increasing transparency in the routing of orders by brokers and wholesalers. Investors should have access to the best-priced quotations available in the National Market System (NMS) to ensure a level playing field for all. To achieve this, I recommend that ATS submit detailed disclosures about their operations, including how they manage conflicts of interest, operate order routing practices, and handle customer orders. This would make it easier for investors to understand how ATS operate and how their orders are executed. ATS should also establish and enforce written policies and procedures to prevent fraudulent and manipulative practices. Furthermore, I support the implementation of 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. 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. I also urge the SEC to create a competitive market structure that benefits investors and encourages transparency. Competition in the marketplace is necessary to regulate markets better, and barriers to competition, such as the conflicted nature of payment for order flow (PFOF), should be removed. To achieve this, 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. Lastly, I support any initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. 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. By increasing transparency, implementing variable pricing models, and removing barriers to competition, the SEC can promote fair and transparent trading practices and protect individual investors from abusive practices in the ATS market. Thank you for your consideration. Sincerely, Kevin Cano Kevin Cano | Data Base Reporting Analyst Grow with us apply @ www.freshexpress.com/careers Fresh Express Incorporated | �� +1-4074076125057 x217 5057 | �� +1-4074072212948 PRIVATE COMMUNICATION: The information contained in this e-mail message is confidential and may be legally privileged. If you are not an intended recipient of this e-mail, be aware that any use, disclosure, publication, distribution or copying of this e-mail message or any part of its content is prohibited and may be unlawful. If you have received this e-mail message in error, please notify the sender and delete the e-mail message from your system.