| Earlier this week, STA filed its comment letter on the SEC’s proposed amendments to improve transparency on how orders are handled. While our letter makes several mentions on the benefits that transparency brings to investors, there is one point we felt deserved a special mention, if for no other reason than it is a narrative response in a world that increasingly demands measureable metrics. The term, “customer experience” is a relatively new, but common expression used by and among retail brokerage firms. We felt compelled to highlight this, because it is our view that the primary catalyst for retail customers in determining where to execute their trades is the comprehensive experience they have with their executing broker-dealer. This includes but is not limited to the explicit and implicit costs of executions. While the proposal seeks to provide customers with additional disclosures not afforded them today, it is STA’s view that the primary driver used by retail customers will continue to be through their experiences with the broker-dealer executing their trade. Yes, transparency is a good thing for reasons stated in the proposal and undoubtedly in the comment letters. But we, as an industry need to remain cognizant that human beings will make decisions based on personal experience as opposed to what is and what is not disclosed to them. A new restaurant with a great review will get people to eat there the first time, but it will be the customer experience that will determine whether they return. This does not mean that all the efforts to draft, respond and ultimately implement the SEC’s proposal are for nothing, quite the contrary. The mere fact of having to disclose information motivates any service provider to improve its performance and for that reason alone, investors are well served. We just need to keep things in perspective and not rely on any one offering on servicing the needs of our customers. They need more than just disclosures on how and where we route and execute orders. They need the customer experience. STA thanks the Commission and all the staff responsible for designing the requirements of this worthy policy goal and look forward to working together on its final design and implementation. STA comment letter here |