Subject: []S7-32-22: WebForm Comments from Anonymouse
From: Anonymous
Affiliation: Household Investor

Mar. 31, 2023



 March 31, 2023

 Dear SEC,

As an individual investor, I support this rule's proposal to bring more transparency to the market by promoting competition and removing conflicts of interest across the board for the various brokers and wholesalers who route the orders of the investing public, all for said routed order to execute at the best price for the investor.

Broadly speaking, I feel that any unfair advantage should be removed and no participant (be it market maker, broker, wholesaler, exchange, or any other party) should have an upper hand when it comes to the market. Any who seek to get around this standard should be held accountable and face very real consequences for the very real attempt to elevate themselves and operate outside of the fundamental framework of the market.

I support this rule in its intentions to make the markets a fairer and more competitive place, and ensure Alternative Trading Systems (ATS) follow the same rules as other exchanges.

Concerning ATS, I would additionally ask that the Commission put great attention toward getting as much detail as possible from ATS in the form of disclosures that document in-depth how ATS operate, handle conflicts of interest, manage and route orders from investors. These disclosures would allow for increased transparency and give investors full confidence in knowing that their orders are being executed fairly by ATS.

I would also like to see the Commission guide ATS to establish their own publicly available written rules and procedures to curb fraudulent activity and increase credibility in the eyes of investors. Further, ATS should work closely with the SEC to follow these procedures and report all data (the execution of orders, order routing practices, and information about the use of dark pools) to the SEC. Doing so will make the SEC's job easier when it comes to regulation and ensuring compliance when it comes to overseeing ATS.

It is important for ATS to carry themselves consistently in-line with the broader rules that have been set in place for the securities markets, which will further enhance fair and transparent trading across the board.

I will also ask that ATS be required to implement a variable minimum pricing increment model for both quoting and trading of NMS stocks.

When it comes to the potential banning of PFOF, I would like to ask that a cap should be implemented for brokers who may charge high commissions or fees to get around the ban.

I support all rules that bring more competition, fairness, transparency, integrity, and balance to the markets. Thank you for reading and for the opportunity to voice my thoughts.