Mar. 31, 2023
Dear SEC, I am writing to express my strong support for the proposed rule changes aimed at promoting fair and transparent trading practices in the securities markets. As an individual investor, I believe that the proposed changes would help to protect me and other household investors from abusive practices in the ATS market, reduce conflicts of interest by increasing transparency in the routing of orders, and promote a competitive market structure that benefits investors. The proposal to implement a variable minimum pricing increment model for both quoting and trading of NMS stocks would promote fair pricing across trading venues, which is essential for ensuring a level playing field for all investors. This would ultimately benefit individual investors by providing them with access to the best priced quotations available in the NMS. I also believe that ATS should submit detailed disclosures about their operations, including how they manage conflicts of interest, how they operate their order routing practices, and how they handle customer orders. This would make it easier for investors to understand how ATS operate and how their orders are executed. Furthermore, ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices. It is essential that ATS 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. This would improve the SEC's ability to oversee ATS and ensure compliance with regulatory requirements. ATS should operate in a manner that is consistent with the broader regulatory structure of the securities markets, which would benefit individual investors by promoting fair and transparent trading practices. I strongly believe that 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. This would help to create a competitive market structure that benefits investors and encourages transparency. I fully 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. Therefore, I urge the SEC to prioritize creating a competitive market structure that benefits investors and encourages transparency. Thank you for considering my comments on this important matter. Kind Regards