Mar. 31, 2023
Vanessa Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington DC 20549 Ms. Countryman: I support this proposed rule. Standards and uniformity are essential to the proper functioning of most public and private infrastructures, our market infrastructure is no different. Adopting this rule, applying the same rules as our regular exchanges to Alternative Trading Systems, and requiring transparency from the ATS on their operations will create an infrastructure that is easier to access, and more efficient in operation. Just as the markings and signage on America's public roadways are consistent, no matter what state one is driving in, so too should the various trading systems allowed in our market also conform to a set standard. The increased uniformity will result in greater consistency of execution in trading, and consistency *is* quality. Especially in the context of household participants in our markets, the American citizen, consistency will create increased confidence in our market and promote fairness. Uniformity and consistency will aid in investor education, as they will know what to expect - independent of which trading system they use to access our market. This uniformity will also result in benefits to the operators of the ATS systems - retail customers will more readily transition between ATS systems based on genuine competitive advantage as they will have confidence in how their trading will be conducted across services. Ultimately any Alternative Trading System that is not already holding itself to the same standards of operation, transparency and reporting as the regular exchanges, is currently doing so by choice. Following that conclusion, that choice not to meet those standards would is due to either a lack of effort or unfortunately, so that trades can be conducted which do not follow the rules which are enforced on the regular exchanges. In that light one fails to see how these ATS, in current form, purport to contribute to fair, open, free, or efficient markets. I feel that this rule is very important, and that when combined with the proposed 34-96495: Order Competition Rule the market will see a drastic course correction towards a more fair and better functioning market. Thank you for your consideration. -janson