Mar. 06, 2023
To whom it may concern; Every rule the SEC passes is only as good as the enforcement that backs it; I want to see higher fines that actually serve as a significant deterrent. Currently the fines are just another 'cost of doing business' - It should be significantly more costly to break the rules than to follow them which is currently what happens. More broker-dealers should lose their licenses instead of receiving fines. I am aware that some do, however the amount that are actually punished by license removal is inconsequential. 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 (https://files.brokercheck.finra.org/firm/firm_116797.pdf). I would gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. I fully support the harmonization of tick sizes across all exchanges. I was shocked 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; this leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are supposed to be fair to household investors and corporate investors alike - why are they not already this way? I vehemently oppose the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. 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. E.g., Some funds and firms might request language like "has a reasonable amount of liquidity at the NBBO". Loose language makes enforcement difficult or impossible, and wastes taxpayer dollars on needless litigation time. 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. For enforcement to be reliable, the rules must be clear and accurate. What is a "reasonable amount"? Who makes that judgement call? What if others disagree? Clear expectations result in clear understanding. I support the inclusion of odd lot information in the SIP, and applaud the Commission's efforts to provide household investors with more information with which to make better investing decisions - especially concerning which firms are allowed to handle our orders. Two years ago, the majority of trades in the markets were odd lots (55%; from https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing). For certain tickers, this proportion is certainly much higher. Why are the bids and offers of so many orders kept invisible? If the Commission were to remove odd lot information from this rule, my faith in the U.S. markets would become even more damaged than it already is. We need MORE transparency, not less. I believe 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 household investors - most of the voting public. Please look into a way to fairly and proportionately include odd lots in the calculation of the NBBO. Thank you for your time. Dave Champagne A concerned household investor.