Subject: SR-NYSE-2022-20: WebForm Comments from Michael Rizzo
From: Michael Rizzo
Affiliation:

Aug. 10, 2022



 August 10, 2022

 This comment is in response to New York Stock Exchange, Inc. (NYSE or Exchange) SR-NYSE-2022-20 and the Proposed Rule Change, as Modified by Amendment No. 1, to Add Subparagraph (f)(1) Regarding Directed Orders to NYSE Rule 7.31. I will make this comment very brief. In no way should this rule be approved by the SEC. There are already numerous dark pools that currently execute trades and to add another one only compounds the problem of true price discovery. Commissioner Gensler has already stated in an interview in 2021 that 90-95% of retail trades do not get executed on the lit exchanges. Adding another dark pool and this one for the NYSE will only compound the issue of directing more trades to be executed off the lit exchanges.

As many are well aware, dark pools give institutional investors the ability to execute large trades without causing markets to move against them. Formee SEC Commissioner Luis Aguilar once wrote that Dark pools initially portrayed themselves as havens from predatory traders. Retail traders already have a distrust for dark pools and how they are used, and approving this does nothing to fix that.

I would also like to include the link to a Reuters article published on 6/17/2021 where Stacey Cunningham, president of Intercontinental Exchange Inc's (ICE.N) NYSE discusses how problematic it is that many of retails favorite stock order flow is traded off exchange, https://www.reuters.com/business/meme-stock-prices-may-not-properly-reflect-demand-nyse-president-2021-06-16/. How did we go from the Stacy Cunningham stating that dark pools are an issue to the NYSE now wanting to direct trades to the very tool that has created so much controversy?

Therefore, I am urging the SEC to vote against this rule to allow the NYSE to direct trades to a dark pool.

Thank you very much

Michael Rizzo