December 3, 2018
Mr. Brent J. Fields
Secretary
U.S. Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549
Re: Transaction Fee Pilot for NMS Stocks, Securities Exchange Act Release No.
82873 (March 14, 2018), 83 FR 13008 (March 26, 2018) (File No. S7-05-18)
Dear Mr. Fields:
I believe that not enough time has been spent looking at the lack of lit volume on thinly traded stocks with wide spreads(2% and more of price).
The adverse selection to lit quotes created by ATS trading has the effect of widening the spread even more, which only benefits ATS liquidity providers.
I suggest a single trading market('trade at') for certain issues that trade very low volumes with wide spreads.
Thank you and kindest regards,
JA