Subject: S7-30-22: WebForm Comments from Max Garrison
From: Max Garrison
Affiliation:

Dec. 27, 2022

December 27, 2022

 I am a retail investor writing to express my support for this proposal. I strongly believe that trading in many stocks would be improved if competitive market forces could establish prices in sub-penny increments and enable buyers to obtain lower prices from willing sellers and sellers to obtain higher prices from willing buyers. Allowing for variable minimum pricing increments for virtually all trading (especially trading on exchanges) will allow retail investors to have their orders executed on-exchange and gain the benefit of a more competitive bid-ask spread there, rather than having their orders routed to dark pools and other ATS which essentially only benefits the wholesalers who use them 'on behalf' of the retail investors.


I expect you will hear much pushback from wholesalers and the like. Wholesalers want to keep the benefit of scraping pennies or fractions of pennies off traders in their own internal systems. While they do give a small fraction back to the retailer as 'proof' that they provided price improvement, this is nothing more than a token, as they pocket the majority of the arbitrage in the tighter bid-ask spread.

Any wholesaler who argues against this proposal, especially any who purport to be acting in retail's best interest, cannot be taken seriously. Their business model is to profit off retail orders by executing these orders off-exchange where they can leverage the different rules in tick sizes between lit and off-exchanges. Leveling the playing field of these tick sizes should benefit retail investors, and for this reason, I voice my support for this proposal.

Thank you.