Mar. 31, 2023
Dear SEC Commissioners, I am writing to express my strong support for the proposed changes to Alternative Trading System (ATS) rules that promote better alignment with regulatory frameworks for exchanges. These changes will benefit individual household investors by increasing transparency in the routing of orders by brokers and wholesalers, and providing detailed disclosures about their operations, including how they manage conflicts of interest and how they handle customer orders. I urge the SEC to require ATS to establish and enforce written policies and procedures to prevent fraudulent and manipulative practices, and 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 will improve the SEC's ability to oversee ATS and ensure compliance with regulatory requirements. Additionally, I strongly recommend that ATS 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. Competition in the marketplace is necessary to regulate markets better, and barriers to competition, such as the conflicted nature of PFOF, should be removed. I believe that sending orders to a wholesaler for internalisation should not be the only option available to investors, and that brokers should not be allowed to charge high commissions or fees in lieu of PFOF without a cap. Estimated savings for retail investors range from $1.12 billion to $2.35 billion, primarily through increased competition to supply liquidity to marketable orders. Household investors support any initiatives aimed at identifying and preventing fraudulent practices that undermine the credibility, integrity, and functionality of American markets. In conclusion, I urge the SEC to prioritize creating a competitive market structure that benefits investors and encourages transparency, and to take all necessary steps to regain public confidence and trust in the market, particularly in light of recent events that have highlighted the need for greater regulatory oversight. Thank you for your attention to these important matters.