Mar. 3, 2023
March 3, 2023 Dear SEC, I am writing to express my strong support for the proposed SEC rule S7-30-22, also known as Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders. This rule aims to improve the transparency and fairness of the securities markets by establishing minimum pricing increments, regulating access fees, and promoting the transparency of better-priced orders. I believe that this proposed rule is essential to ensure that investors receive fair prices for their securities transactions, and that market participants are able to compete on a level playing field. Minimum Pricing Increments: The proposed rule would establish minimum pricing increments for securities that trade in increments larger than $0.01 per share. This would help to ensure that investors receive fair prices for their securities transactions, as well as reduce market complexity and confusion. Currently, trading venues can use pricing increments as small as $0.0001 per share, which can result in an unfair advantage for high-frequency traders and other sophisticated market participants. The proposed rule would establish minimum pricing increments of $0.005 per share for securities priced above $1, and $0.001 per share for securities priced below $1. This would help to promote fair competition among market participants, as it would prevent certain market participants from gaining an unfair advantage by exploiting small pricing increments. The minimum pricing increments would also help to reduce market complexity and confusion, as there would be fewer price points for investors to track. Access Fees: The proposed rule would also regulate access fees, which are fees that trading venues charge for providing access to their market data and trading services. Access fees can vary widely between trading venues, and can be a significant expense for market participants, particularly smaller ones. The proposed rule would limit access fees to a reasonable level, based on the cost of providing access to the trading venue. This would help to ensure that trading venues are not unfairly profiting from access fees, and would promote fair competition among trading venues. Transparency of Better-Priced Orders: The proposed rule would also promote the transparency of better-priced orders. Currently, trading venues can execute orders at prices that are better than the prevailing market price, without providing information about the size of the order or the identity of the party submitting the order. This can result in market fragmentation and unfair advantages for certain market participants. The proposed rule would require trading venues to provide information about the size of better-priced orders and the identity of the party submitting the order, which would help to promote transparency and fair competition among market participants. Conclusion: Overall, I believe that the proposed SEC rule S7-30-22 is essential to improve the transparency and fairness of the securities markets. The minimum pricing increments, access fees, and transparency of better-priced orders would help to promote fair competition among market participants and ensure that investors receive fair prices for their securities transactions. I urge the SEC to finalize this rule as soon as possible, to protect investors and promote fair competition in the securities markets. Thank you for considering my support for this important proposal. Sincerely, Chris Robinson