Sep. 13, 2023
Apologies for this follow-up question…I read the brief intently and meant to comment earlier. Proposed Rule 1101(c) would require broker-dealers to review at least quarterly the execution quality of their customer transactions; compare it with the execution quality that might have been obtained from other markets; revise accordingly their best execution policies and procedures, including order handling practices; and document the results of the review. My question is related to governance specifically to ETF wrappers. Specifically, in the ETF world, the advisor, especially in passive instruments, tries to achieve the lowest tracking error or lowest transaction costs, among other things. Is there a similar rule like 1101 for the advisor and not the broker/dealer? Does this make sense? John Regino Flex Axion john.regino@flexaxion.com 201-710-0510