Mar. 31, 2023
Conflicts of interest are unacceptable weaknesses in our country's market that eat away at any true progress that can be achieved in our country. Demaning transparency in the routing of orders by brokers and wholesalers is a necessity to remove such draining ailments from our economy. Investors having access to the best priced quotations available in the NMS will infuse our markets with a strong foundation with which household investors can build trustworthy wealth upon. The proposed changes to ATS (Alternative Trading Systems) rules promote better market alignment with regulatory frameworks for exchanges and would be beneficial for individual household investors. 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, as well as prove to investors that the market is fair, consistent, and worthy of investment. ATS should establish and enforce written policies and procedures to prevent fraudulent and manipulative practices. This would help to protect individual investors from abusive practices in the ATS market. 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. 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. ATS should implement 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. 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 and trust in our investments. I support any initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. Sending orders to a wholesaler for internalisation 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. Estimated savings for retail investors range from $1.12 billion to $2.35 billion, primarily through increased competition to supply liquidity to marketable orders. Which will encourage more market activity, as investors will have more capital to invest with. Competition in the marketplace is necessary to regulate markets properly. Barriers to competition, such as the counter-intuitive nature of PFOF, should be removed. The SEC should prioritise creating a competitive market structure that benefits investors and encourages trust and transparency.