Dec. 27, 2022
December 27, 2022 RE: File Number S7-30-22: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders: This rule addresses the practice of penny shaving and will bring an end to it. I strongly support this. The proposed changes to tick sizes, access fee caps, and transparency for better priced orders will likely have a significant impact on order routing and execution. The most important aspect of these changes is the modification of tick sizes. Currently, internalizers have a regulatory advantage over exchanges because they can execute orders at any pricing increment, which is why we see many 1 mil price improvement trades and prices with four decimal places. These changes would eliminate this practice and create a level playing field. This means that retail investors will have the same opportunity to get price improvement on-exchange and will change the incentives for retail brokers. Additionally, lowering the access fee cap (the fee that exchanges can charge for orders that take liquidity) to 5-10 mils depending on tick size will make it less expensive for brokers to route orders to exchanges, making them more competitive. Sincerely, Lukas Boller Engineer, Retail Investor