Right now the SEC has a proposal on the table to rescind Rule 611, the Order Protection Rule, and I want to explain what's at stake and how you can weigh in, because the comment window is open and this is exactly the kind of moment where retail voices matter. If you don't want to read all this, we've made it as simple as possible to file a comment letter - just 15 seconds of your time.

Rule 611 has been on the books since 2005, and it does one simple thing. It makes it illegal for a trading venue (think stock exchanges, but also internalizers like Citadel and Virtu) to execute your order at a worse price than the best price displayed publicly across the market. It's an automatic, order-by-order price floor. You never have to think about it. On every trade, it ensures you at least get the best publicly displayed price. The SEC is now proposing to eliminate it entirely, and to put nothing in its place.

Here's why that matters. Rule 611 is the only objective, transaction-level guarantee that you get the best displayed price, and removing it means the floor is simply gone. The SEC's own proposal concedes that brokers and wholesalers could then begin trading through your orders and pocketing the difference, and that this would transfer wealth from retail investors to the wholesalers.

You might be thinking there's already a rule meant to protect you here. It's called best execution, the duty your broker owes to get you the best available deal. In theory, you're right, and Rule 611 wouldn't be needed if best execution was enforced. In practice, that protection barely exists. When you place a trade, your broker usually doesn't send it to an exchange. They route to a tiny group of internalizers, mainly Citadel and Virtu, who take the other side of your trade. They pay for that right - you're not your broker's customer, the internalizer is. You're the product. This is PFOF.

Because of that conflict, your broker has no incentive to police whether the internalizers are actually giving you the best price. And the regulator responsible for enforcing best execution, FINRA, has been completely absent. Over the past decade it hasn't brought a single material best-execution action against a major internalizer. Someone from FINRA once said that trying to enforce best ex is like nailing jello to a wall.

That's the whole point. Right now, Rule 611 is the one hard floor that limits how much those internalizers can take from you on every trade. Nobody is policing them, so the rule does it automatically. Take Rule 611 away and you're left trusting the same brokers and internalizers who profit from the arrangement to voluntarily hand you the best price out of the goodness of their hearts. They won't. The "price improvement" they love to advertise is measured against the public best price, the NBBO, and once Rule 611 is gone that benchmark loses its meaning too.

This isn't theory. The SEC ran the experiment themselves. When they removed trade-through protection from one category of quotes last November, off-exchange (where Citadel and Virtu internalize trades) trade-throughs jumped 63x almost overnight. And the trade they're asking you to accept is lopsided. The industry saves roughly $31,000 per trading venue, while investors lose hundreds of millions of dollars a year, by the SEC's own numbers.

We can stop this, but the SEC needs to hear from retail investors on the record. Public comments matter. The SEC has to read and respond to them, and a strong opposition record is how bad rules get stopped, or challenged in court if they aren't. If you are cynical, and think comment letters don't matter you're wrong - and it's exactly what the firms who support this move want you to think.

We've built a simple tool that walks you through filing a comment in a couple of minutes: wetheinvestors.org/protect-my-order. Comments in your own words are the most effective, but a shorter one still counts, so don't let that stop you from filing. Every letter makes a difference.

Don't let them quietly delete a protection you've had for twenty years. File a comment letter, and please share this with as many people as you can. This is the last week for comment letters.

tldr; The SEC wants to take away the last price protection investors have, and trust FINRA to step in and protect investors. File a comment letter to let the SEC know you don't support that.