Mar. 31, 2023
Dear Secretary Countryman, Thank you for this opportunity to comment on this proposal. I identify as a retail investor. I support this Best Execution proposal. Because brokers are agents for their customers, including retail investors, they would best serve them by utilizing Best Execution, specifically without the use of Payment For Order Flow. It is common knowledge that the current PFOF allows wholesalers to access a large swath of the market and conduct faster trades prior to other market participants. Yet wholesalers falsely claim these practices as beneficial to retailers, citing commission-free trading. Commission-free trading, which many retailers use, is entirely possible without the avenue of Payment For Order Flow. This is evidenced by Fidelity’s trading platform. Wholesalers’ colorful re-definitions of PFOF arrangements do not change the reality of PFOF. In essence this re-routing of orders overwhelmingly benefits wholesalers while unfairly leaving retail investors without a best price offer. Poorly matched trade executions experienced by retailers can lead to missed opportunities and missed information. A subsequent lack of information would inhibit successful transactions then further attempted by retail investors. By its very nature PFOF is simply not consistent with the heart of Best Execution. This proposed rule provides a equalizing standard for broker-dealers to follow. By allowing this proposal for Best Execution, transparency and honesty will at last have a chance to shine through, illuminating clearly the market as fair for all participants. Again, Secretary Countryman, thank you very much for this opportunity for my comments to be recognized. Sincerely, Wendy McBee