Highlights Rule 605 Changes That Will Further Weaken Justification for the Proposals
WASHINGTON – Barbara Comstock, Executive Director of the American Consumer & Investor Institute, today filed comments with the U.S. Securities and Exchange Commission (SEC) calling for the withdrawal of four proposed rules in light of updated new Rule 605 reporting metrics that are expected to further weaken the already-flawed justifications and economic analyses for those proposed rules.
“There has never been justification for the Proposed Rules, as ACII explained previously,” American Consumer & Investor Institute Executive Director Barbara Comstock wrote in the comment letter. “The significant enhancements to Rule 605 are yet more reason those proposals should proceed no further. ‘Rules are not adopted in search of regulatory problems to solve; they are adopted to correct problems with existing regulatory requirements that an agency has delegated authority to address.’ If the amendments to Rule 605 significantly improve execution quality, as the Commission anticipates, there is ‘no rational basis’ for further action.”The comment letter addresses four proposed SEC rules: Order Competition Rule; Regulation Best Execution; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders; and Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers.ACII has previously filed comments opposing all of these proposed rules (available HERE and HERE) and raising the alarm on the negative impact they would have on retail investors.
Read the full SEC comment letter filed today HERE.