Mar. 06, 2023
Dear Sir/Madam, As a household investor, I am writing to express my deep concern about the state of the market and the lack of enforcement of SEC rules. Every rule the SEC passes is only as good as the enforcement that backs it. Unfortunately, I have seen far too many cases where broker-dealers receive insignificant fines that do not serve as a deterrent. This is unacceptable and must change. I strongly believe that 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”. The fines imposed on such broker-dealers should be high enough to serve as a significant deterrent. 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. I would also pay a commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. It is essential that investors have confidence in the integrity of the market, and routing orders through such wholesalers undermines that confidence. I fully support the harmonization of tick sizes across all exchanges. It is shocking 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. The markets are supposed to be fair - so make them fair. I strongly 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". This would help ensure that investors receive the best possible execution for their trades. 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. 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 also 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. 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. In conclusion, I urge the SEC to take action to enforce its rules, harmonize tick sizes across all exchanges, reduce access fees, and include odd lot information in the SIP. These actions will help ensure that investors have confidence in the integrity of the market and receive fair treatment. Thank you for your attention to this matter. Sincerely, Adam Barcellona