Mar. 31, 2023
Every rule the SEC passes is only as good as the enforcement that backs it, and that enforcement only matters if the men and women doing the enforcement have personal integrity and is willing to do the right thing. So far looking over some of the rules this self regulated market it seems there is no integrity at all and thats why you are having so many writing in. You see the average person is to dam busy making sure they do there job right it's insanely asinine that so many of us have to get involved because you guys just would not look out for us or even your loved ones. It's carzy how important money is to everyone working for it and you sit there and watch them steal if from us every day. Taking BILLIONS from us who are out here actually making things. It's disgusting and shameful so here we are acting like we need to point out the obvious to you in a nice way hoping you do the right thing. What happens when we loose hope? I not only want to see higher fines that actually serve as a significant deterrent let's start with 100% of whatever profits made (I believe that is already a rule you guys should know) plus 50%. But that's just the beginning we need jail time. I mean let's be real when is it ever ok to steal that amount of money and not go to jail. In mean a felony in most states starts at like $500 I have no idea but you probably didn't either and that's my point. How can you expect us to let you sit there and do nothing when so much is wrong. I know rules and all that BS but that's my point they made the rules for them you know the rules but don't enforce the ones you know can make a difference, let them change rules out of nowhere with little to know push back (not reporting swaps for two years). I think some broker-dealers should lose their licenses instead of receiving fines that amount to nothing more than a cost of doing business - a cost that is often outweighed by the ill-gotten gains obtained through “honest mistakes”. I would gladly pay 12 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government (https://files.brokercheck.finra.org/firm/firm_116797.pdf). I would gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. I fully support the harmonization of tick sizes across all exchanges. I was shocked to learn that some exchanges get special treatment and are able to leverage that special treatment to build monopolies in some areas of the market. All exchanges should have to quote AND trade in the same increments. Some exchanges shouldn’t be granted an unfair advantage over others. It leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are supposed to be fair - so make them fair. I dislike the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. I would prefer you reduce access fees to zero; no "take". I support the tick size regime proposed by the Commission, and would also support any structure that is clear and does not rely on vague language. For example, some funds and firms might request language like "has a reasonable amount of liquidity at the NBBO", which translates to "I can ignore the rule if I feel my lawyers can help me get away with it". Loose language makes enforcement difficult or impossible, and wastes taxpayer dollars on needless litigation time. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules. I support the inclusion of odd lot information in the SIP, and applaud the Commission's efforts to provide individual investors with more information with which to make better investing decisions - especially concerning which firms are allowed to handle our orders. Two years ago, the majority of trades in the markets were odd lots (55%; from https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/). For certain tickers, this proportion is certainly much higher. Why are the bids and offers of so many orders kept invisible? If the Commission were to remove odd lot information from this rule, my faith in the U.S. markets would become even more damaged than it already is. I believe the exclusion of odd lots from the NBBO is a problem. Odd lots are now a majority of trades in the markets. Within some stocks, they are the vast majority. The exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors - most of the voting public. Please look into a way to fairly and proportionately include odd lots in the calculation of the NBBO.