Mar. 31, 2023
Dear SEC, I am writing to express my strong support for initiatives aimed at reducing conflicts of interest in the routing of orders by brokers and wholesalers. I believe that increasing transparency in this area, and giving investors access to the best-priced quotations available in the NMS, would be of great benefit to individual investors. I fully support the proposed changes to ATS rules, which promote better alignment with regulatory frameworks for exchanges. These changes would be particularly beneficial for individual household investors, who often lack the resources and expertise to navigate the complexities of the market. I urge the SEC to require ATS to 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. In addition, 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. I also support the proposal to require ATS to 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. Furthermore, I believe that ATS should operate in a manner that is consistent with the broader regulatory structure of the securities markets. This would benefit individual investors by promoting fair and transparent trading practices. I strongly support the implementation of a variable minimum pricing increment model for both quoting and trading of NMS stocks. This would promote fair pricing across trading venues, which is essential for ensuring a level playing field for all investors. It is critical that we identify and prevent fraudulent practices that undermine the credibility, integrity, and functionality of American markets. I urge the SEC to prioritize creating a competitive market structure that benefits investors and encourages transparency. Finally, I support the introduction of a cap on commissions or fees charged by brokers in lieu of PFOF. This would increase competition to supply liquidity to marketable orders, resulting in estimated savings for retail investors ranging from $1.12 billion to $2.35 billion. Thank you for your attention to this matter. Sincerely, April Woods