Pennsylvania State Action

Pennsylvania Attorney General Dave Sunday: The Case for Investigating Citadel Securities

Dave Sunday, the Pennsylvania Attorney General, has the authority and — given the documented harms to an estimated 2.5 million Pennsylvania retail investors — the obligation to investigate Citadel Securities' payment for order flow practices under Pennsylvania law.

The AG's Authority in Pennsylvania

Pennsylvania Attorney General Dave Sunday and the Pennsylvania Securities Commission have authority under the Pennsylvania Securities Act of 1972 (70 P.S. §1-101 et seq.) to investigate broker-dealer conflicts.

The Harm to Pennsylvania Investors

Pennsylvania's large industrial working class — from Pittsburgh steel country to Philadelphia's port district — has significant retirement savings managed through 401(k) plans and discount brokers. PFOF practices extract value from these workers' savings without transparency.

Dave Sunday has an estimated 2.5 million Pennsylvania retail investors as potential complainants. This is not an abstract regulatory question — it is a matter of whether Pennsylvania's chief law enforcement officer will protect the financial interests of Pennsylvania residents when federal regulators have failed to act.

The Griffin Political Context

Pennsylvania Attorney General Dave Sunday should be aware of the documented political investment Kenneth Griffin has made in Pennsylvania. Griffin has given millions in Pennsylvania-linked political contributions to Senator Pat Toomey and the NRSC that invested heavily in Pennsylvania's 2022 Senate race. 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 Pennsylvania consumer protection law by creating undisclosed conflicts of interest
Whether Pennsylvania broker-dealers are meeting best execution obligations under state securities law
Whether Citadel Securities' disclosures to Pennsylvania retail investors adequately describe the PFOF relationship
Whether a multistate investigation coordinated through NASAA would be appropriate

Contact Dave Sunday

Pennsylvania residents can contact the Attorney General's office at https://www.attorneygeneral.gov to request investigation of PFOF-related broker-dealer practices affecting Pennsylvania investors.

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