Mar. 31, 2023
These recommendations focus on improving transparency, fairness, and efficiency in the stock market. They address concerns such as high-frequency trading, rebates, and the need for clear and unambiguous rules. The proposed tick size regime aims to improve market quality by setting minimum price increments for quoting and trading of NMS stocks. This would promote fair pricing and reduce the potential for market manipulation. The call for a zero or very low fee structure, instead of allowing rebates and other inducements, aims to eliminate the incentive for trading for the sake of volume. This would help ensure that trades are made for genuine investment purposes, rather than for financial gain. The variable minimum pricing increment model is another measure to promote fair and transparent pricing across trading venues. By applying to both quoting and trading, it would ensure that all participants are subject to the same rules. Reducing access fee caps is a step in the right direction, but completely eliminating exchange rebates would further enhance transparency and fairness in the market. This would help ensure that brokers are making decisions based on their clients' best interests, rather than for financial gain. The revised round lot definition and odd lot dissemination on the SIP would enhance reporting efficiency and reduce delays. By making it clear that odd lots should impact the NBBO and have a concrete effect on price and broker's duty of best execution, investors would have a better understanding of market conditions and make more informed investment decisions. Overall, these recommendations aim to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement measures such as higher fines and bigger penalties are also necessary to ensure that rules are followed and consequences are in place for those who break them. Thank you for your time.