Subject: Re: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22)
From: Chris Duerr
Affiliation:

Mar. 07, 2023

I fully support this rule of harmonization of tick sizes across all exchanges. I never really fully understood why some tickers I follow would all of the sudden trade with 3 or 4 digits after the decimal point. I think we can all agree this  is unnecessary and clearly someone is tipping the scales in their favor. I feel like all exchanges should have to quote and trade in the same increments.  


Some funds and firms may request vague language like “has a reasonable amount of liquidity at the NBBO” which in my opinion, leads to lax enforcement. I support the language endorsed by the Commission in the rule.  


These firms have commented on this rule and like to say that their interests are in line with mine, the retail investor. But I can say with certainty that it does not feel like that. If this is what “free” trading looks like, I’ll gladly pay for each trade to avoid certain wholesalers having monopolies on the market and front running my trades.  


To that end, I also feel like offering rebates creates payment for order flow, which is also another method used to front run retail trades and not provide the best order execution for each individual trade nor for price discovery for any individual security.  


I also believe the exclusion of odd lots from NBBO is an issue. Odd lots make a majority of trades and are generally trades from retail investors. If these trades are excluded from price discovery, do we truly have price discovery?  


Thanks for your time, 


Chris Duerr