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

Mar. 06, 2023

 


Dear SEC, 

As a household investor, I am extremely disappointed with the current state of the financial markets. Every rule that the SEC passes is only as good as the enforcement that backs it. Unfortunately, the enforcement has been severely lacking, and it's time for the SEC to step up and take action. 

Firstly, fines need to serve as a significant deterrent. I want to see higher fines that actually deter bad behavior, instead of just being a cost of doing business. Some broker-dealers should lose their licenses instead of receiving fines that are outweighed by the ill-gotten gains obtained through "honest mistakes." 

Secondly, I am willing to pay more to avoid being routed through wholesalers with a long record of flouting the law, like Citadel Securities. I would gladly pay commission to avoid being routed through them, especially when they have been charged over 70 times by the United States government. 

Thirdly, I fully support the harmonization of tick sizes across all exchanges. It's unfair that some exchanges get special treatment and are able to build monopolies in some areas of the market. All exchanges should have to quote and trade in the same increments. The markets are supposed to be fair, so please make them fair. 

Fourthly, rebates and other inducements in the marketplace are simply payment for order flow by another name. I would prefer you reduce access fees to zero, with no "take." 

Fifthly, 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, which only make enforcement difficult or impossible and waste taxpayer dollars on needless litigation time. 

Lastly, I support the inclusion of odd lot information in the SIP. Odd lots are now a majority of trades in the markets, and the exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors. Please look into a way to fairly and proportionately include odd lots in the calculation of the NBBO. 

In conclusion, I hope the SEC takes these concerns seriously and takes action to make the markets fair and transparent for all investors. It's time for the SEC to enforce its rules and restore confidence in the financial markets. 

Sincerely, 


-- 

Christian Roy