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

Mar. 06, 2023




Hello for all of those who are concerned, before I step into my complex argument I want to say this; 
(Quick side note, household investors are meticulously reviewing all of these steps and ask you to make common sense moves that would actually affect household investors. 


I do not want to see the SEC trying to tighten and improve the relationship with customers (hedge funds purposely trying to bankrupt the business). 
Ask household investors for feedback that doesn't include the BS proven, verified lies they will tell you. 


Multiple people testified in front of the US government that the SEC did not do their job in the 2008 financial crisis. It's clear that big hedge funds are ridiculously over leveraged and they are causing risk to the global markets. 


It would be great if the SEC did something to actually protect household investors, like go after those hedge funds who are making bets that are actively trying to deflate the market and cause extreme risk. 




This isn't that complicated if a small business owner with 15 employees can figure this all out, double check it with backed sources that have been double checked, why can't the sec? 


Please, household investors are begging you to get off of your butt and do something. Not put out a tweet that says you might do something in the future. Actual, verifiable reform that will make a big difference. 


posting videos that classify household investors as stupid does not contribute to the sec vision of including household investors it did nothing but exclude us. 


It makes it clear that your actions are not really sticking up for people like me but it's sticking up for hedge funds that have huge gambles in companies going bankrupt. 




In short it is absolutely ridiculous there are certain fund managers, like Citadel who are wholesalers and have the ability to trade in sub Penny increments, while the rest of the market cannot. 




I kindly ask, how is this fair business. I am a household investor. I own a business that employs 14 people. Me and my 14 employees do not have the ability to trade at sub Penny increments like these people do. The rules continually give them the ability to make free money without risking anything. 




SEC PLEASE, IM BEGGING YOU, WHY ARE THE RULES DIFFERENT FOR EVERYONE? IF I BUY A STOCK CAN YOU PLEASE MAKE SURE AND ENFORCE THAT SOMEONE ACTUALLY DELIVERS ME THAT STOCK? 
IF NOT, WHAT ARE WE AS AMERICAN TAXPAYERS GIVING YOU ALL THIS MONEY FOR, SERUOUSLY, I'D BE THRILLED TO READ AND ANSWER HERE.  




The corruption with the SEC and politicians involved is absolutely ridiculous and out of control. 




I hope that eventually someone will stand up and actually speak for household investors and quit listening to the vomit that citadel securities and businesses like it spew out of their mouth in a "defense for retail" and "meme stocks" what exactly qualifies a stock as a meme stock? 












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. 
  
I think 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”. 
  
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. It 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 - so make them fair. 
  
I 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 above point cannot be stressed enough. What is payment for order flow outlawed in all other first world countries except for the United States? 


It doesn't look good when the company is to take advantage of payments to order clothes or huge donors to politicians, this needs to be stopped for obvious reasons. 






  
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. For example, some funds and firms might request language like "has a reasonable amount of liquidity at the NBBO", which translates to "I can ignore the rule if I feel my lawyers can help me get away with it". 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. 
  
I 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. 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. 
  
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 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. 

Thank you, 
Davis Hix