The AG's Authority in Massachusetts
Massachusetts Secretary of the Commonwealth and Securities Division have already taken enforcement actions related to PFOF and best execution. Attorney General Andrea Campbell could amplify this work under the Massachusetts Consumer Protection Act (M.G.L. c. 93A). Massachusetts should lead the nation in a multistate PFOF investigation.
The Harm to Massachusetts Investors
Massachusetts has historically been the most aggressive state securities regulator in the country. Secretary of State William Galvin has brought landmark PFOF-related enforcement actions. Massachusetts investors deserve continued robust enforcement as Citadel's practices persist.
Andrea Campbell has an estimated 1.5 million Massachusetts retail investors — in a state with historically aggressive securities enforcement as potential complainants. This is not an abstract regulatory question — it is a matter of whether Massachusetts's chief law enforcement officer will protect the financial interests of Massachusetts residents when federal regulators have failed to act.
The Griffin Political Context
Massachusetts Attorney General Andrea Campbell should be aware of the documented political investment Kenneth Griffin has made in Massachusetts. Griffin has given millions through national Republican organizations to national Republican committees that have targeted Massachusetts congressional seats. This political context does not determine what the AG should do — but it is relevant to understanding why federal and state regulators have been slow to act, and why an independent state investigation would be meaningful.
What the AG Should Investigate
- Whether PFOF arrangements between major discount brokers and Citadel Securities violate Massachusetts consumer protection law by creating undisclosed conflicts of interest
- Whether Massachusetts broker-dealers are meeting best execution obligations under state securities law
- Whether Citadel Securities' disclosures to Massachusetts retail investors adequately describe the PFOF relationship
- Whether a multistate investigation coordinated through NASAA would be appropriate
Contact Andrea Campbell
Massachusetts residents can contact the Attorney General's office at https://www.mass.gov/orgs/office-of-the-attorney-general to request investigation of PFOF-related broker-dealer practices affecting Massachusetts investors.