Overview

In March, 2022, We The Investors launched our grassroots advocacy campaign and focused our first efforts on ending Payment For Order Flow (PFOF) and excessive off-exchange trading. On December 14, 2022 the SEC announced the most significant changes to US markets in 17 years, and took the first steps towards curbing these practices. We fully support the SEC's efforts, but we believe that the rule proposals can be improved. We are determined to ensure that individual investor interests are properly represented before the SEC and in the public debates and discussions. For too long, conflicted firms like PFOF brokers and wholesalers have claimed to represent individual investors. Those days are over.

Our second comment letter focuses on the proposed Order Competition Rule. In that rule, the SEC has proposed to restrict which orders can be executed off-exchange by internalizers, and mandated that these orders be sent to exchanges and put into auction facilities. While we agree with the goal, we believe a trade-at rule is a simpler and better solution. Our letter supports the SEC proposal and suggests improvements to it, but also makes the case for a trade-at rule.

If you agree with it, please join us in our mission to end this practice by writing your own comment letter (feel free to take any parts of ours you want) or by simply signing your name and filing this letter. There is strength in numbers, and it's time to show the SEC that individual investors have the numbers.

How To File a Comment Letter

If you are interested in filing a comment letter, the simplest and safest way is to do so by email. If you would like to write your own comment letter, we have some guidance and information for you.

NOTE: The deadline for comments for these rule proposals is March 31, 2023.

If you don't have the time to write a letter yourself, we would encourage you to take the letter that we have filed, make sure that you agree with its content, feel free to customize it if you'd like, and then sign and file it. We have linked to two different formats on the right.

When signing a comment letter, you can do so electronically (type your name and position/title at the bottom) or print, sign and scan it.

Please follow these steps to file the comment letter:

1. The subject line must include the File Number. For this proposal, you should use this subject: "Comment Letter for File Number S7-31-22 Order Competition Rule"
2. Attach your comment letter, preferably as a PDF (alternatives include Word or Text docs).
3. Send the email to rule-comments@sec.gov.
4. Share this on social media! Let everyone know that you've gotten involved in the process, that you've put the effort in to make yourself heard, and encourage them to do the same. Use the hashtag #WeTheInvestors or tag us at @WeTheInvestors_