The Virginia State Corporation Commission, Division of Securities and Retail Franchising's Authority
Virginia Attorney General Jason Miyares and the Virginia SCC Division of Securities have broad authority under the Virginia Securities Act (Va. Code Ann. §13.1-501 et seq.) to investigate broker-dealer conflicts affecting Virginia investors.
The Harm Requiring Regulatory Response
Virginia has the largest population of federal government employees and contractors in the nation — many of whom invest through Thrift Savings Plan-adjacent brokers and retail platforms subject to PFOF. The Northern Virginia tech corridor also houses sophisticated retail investors who deserve better execution.
What State Regulators Should Do
The Virginia State Corporation Commission, Division of Securities and Retail Franchising, in coordination with the Virginia Attorney General's office, should:
- Open an investigation into whether broker-dealers serving Virginia residents are meeting best execution obligations under state securities law
- Issue a formal inquiry to major PFOF-dependent brokers about their routing arrangements with Citadel Securities and the execution quality they achieve for Virginia residents
- Contact NASAA to explore multistate coordination
- Issue investor education guidance about PFOF practices and how Virginia investors can protect themselves
- Consider rulemaking under state securities law to require enhanced disclosure of PFOF arrangements affecting Virginia retail investors
Contacting the Virginia State Corporation Commission, Division of Securities and Retail Franchising
Virginia investors and advocates can contact the Virginia State Corporation Commission, Division of Securities and Retail Franchising at https://www.scc.virginia.gov/pages/Securities to report concerns and request regulatory action on PFOF practices affecting Virginia residents.