Mar. 31, 2023
To Whom It may Concern, To the benefit of individual household investors, the proposed changes to the ATS rules promote better alignment within the regulatory frameworks for exchanges. By reducing conflicts of interest and increasing transparency in the routing of orders by brokers and wholesalers, investors will have access to the best priced quotations available in the NMS. To help individual investors understand how ATS operates and how their orders are executed, ATS's should provide detailed disclosures about their operations, and include language about how they manage conflicts of interest, and how they handle customer orders, as well as how they operate their order routing. By establishing and enforcing written policies and procedures, the ATS can help prevent fraudulent and manipulative practices, and better protect individual investors. By operating in a manner that is more consistent with the broader regulatory structures of the securities markets, individual investors would benefit from fair and transparent trading practices. ATS should at minimum provide detailed information about their systems operations to the SEC, and include data on order execution, routing practices and information about their dark pool usage. This would allow the SEC a better ability to oversee ATS and ensure regulatory compliance. The proposal to implement a variable minimum pricing increment model for quoting and trading of NMS stocks is essential for ensuring a level playing field for all investors, by promoting fair pricing across trading venues. Finally, it is my belief that the SEC should prioritize creating a competitive market structure that benefits investors and encourages transparency. This can be done by implementing a cap on high commissions or fees in lieu of PFOF, offering more options outside of sending orders to a wholesaler for internalization, and supporting initiatives that identify and prevent fraudulent practices. Thank you for considering my comments, Matthew Shaw .