Citadel and Viru utilise a "price improvement scheme" to attract order flow by claiming to offer the best trades in the market. While their performance statistics seem to support this, they often do not provide the best price available, but rather a slightly better price. This allows them to gain order flow without needing to pay for order flow.
There is a suspicion that they selectively apply the price improvement to benefit themselves. The new rules aim to enforce legal requirements that should have already been in place and mandate more transparent disclosure of their practices to prevent deception.
This will help to expose any unethical behaviour and prevent them from taking advantage of the market.

• Press Release: https://www.sec.gov/news/press-release/2022-223
• Fact Sheet: https://www.sec.gov/files/34-96496-fact-sheet.pdf
• Disclosure Fact Sheet: https://www.sec.gov/files/34-96493-fact-sheet.pdf
• Other submitted SEC comments here: https://www.sec.gov/comments/s7-29-22/s72922.htm

• Best execution is important in trade execution for individual investors who may not understand the complexities involved in choosing how to execute a trade.
• Provide clear guidance on how to read and interpret the data in Regulation NMS Rule 605 reports, especially for retail investors who may not have a deep understanding of the markets.
• Brokers owe their customers a duty of Best Execution derived from common law agency principles and fiduciary obligations, but it needs to become a rule that the SEC can enforce.
• Conflicted orders don't belong in a Best Execution rule.
• Without the best execution rule, customers may not be aware of revenue arrangements between brokers and subpar trading firms or that they may be paying higher transaction prices.
• Different trading venues may offer different prices, slower execution can lead to missed opportunities. Information leaks can inhibit a successful transaction, and less reliable settlement processes can delay receipt of proceeds.
• In December 2020, Robinhood was charged by the SEC with failure to satisfy its best execution obligation, resulting in an aggregate loss of $34.1 million for its customers.
• Robinhood made misleading statements and did not disclose payments received for routing trades to specific firms.
• Citadel paid the SEC $22.6 million in 2017 to settle best execution charges for executing customer trades at less favourable pricing when a better price was available.
• Brokers recommending mutual funds with 12b-1 fees and revenue sharing arrangements with clearing brokers have also faced best execution charges from the SEC.
• Quarterly reviews of execution quality would provide transparency and accountability for the broker-dealers' practices.
• The proposed rule would provide a more detailed and comprehensive standard for broker-dealers to follow, resulting in consistently robust best execution practices.
• The proposed Regulation Best Execution is a necessary step in protecting household investors and promoting fair and efficient markets by ensuring that household investors are receiving the best possible execution for their trades.

Work smarter, not harder. ChatGPT - https://chat.openai.com/chat - is a AI language model that is designed to help make things easier for you.
Although this remains an unreliable source for verified information and facts (and will always require people to asses/compare/research and cross-reference responses) - this is a writing tool that could be used to help create a basis for your comment.
Simply copy/paste the comment templates and ask the AI language model to rephrase the text (if you don’t already know what to say) and be sure to check the wording when a template is produced.
❗️ ⚠️ REALLY IMPORTANT ⚠️ ❗️ : YOU MUST READ THROUGH AND FACT CHECK YOUR RESPONSES!! SERIOUSLY - YOU MUST PROOF-READ AND FACT CHECK CHATGPT.
You wouldn't want to accidentally submit a comment that agrees with Citadel opposing the rule now, would you?
This AI language model sometimes produces incorrect responses - so if you choose to embrace new technology as a tool/resource to help aid your learning - you must ensure that you are dedicating the same time to be accurate in your prompts, and in your assessment of the content as produced. You are the fact checker, not the AI platform.
Not sure whether ChatGPT is right for you? Check out this guide as below:

To remind ourselves, nothing is truly infallible: the internet, the mainstream media, even our books can become outdated/factually incorrect sometimes - it’s why we need the human element. So we can cross-reference information as obtained, and carry out necessary fact check and critically assess detail across a multitude of platforms. ChatGPT is no different here. It is simply another tool/resource we need to fact check. We should treat it as such.
Happy commenting!

Has that wet your whistle? I bet it has!

• "The Big Four" - https://www.reddit.com/Superstonk/comments/11kz27h/sec_comments_lfg_heres_my_first_draft_that_im/ - courtesy of the wonderful Platinumsparkles 💜
• Instructions from Dave Lauer: https://www.reddit.com/Superstonk/comments/11rw8bt/comment/jcaherb/?context=3
• Other submitted SEC comments here: https://www.sec.gov/comments/s7-29-22/s72922.htm

• Open your email.
• The SEC's email is [[email protected]](mailto:[email protected]%22%20%5Ct%20%22_blank).
• Copy/paste this title into the subject line: RE: File No. S7-29-22; Release No. 34-96493· Disclosure of Order Execution Information
• Use talking points above.
• Rephrase them / write more in your own words.
• Submit.

Vanessa Countryman, Secretary, Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549-1090

• Citadel and Viru use a "price improvement scheme" to attract order flow by offering slightly better trades than the market.
• Their performance statistics seem to support this claim, but there is a suspicion that they selectively apply it to benefit themselves.
• They can gain order flow without needing to pay for it.
• The new rules propose to enforce legal requirements that should have already been in place and mandate more transparent disclosure of their practices to prevent deception.
• The aim is to expose any unethical behaviour and prevent them from taking advantage of the market.
• SUPPORT THE NEW RULE