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

Mar. 06, 2023

 



I would like to see tougher enforcement of SEC rules with consequences that will actually make a difference. 
  
I don't think broker-dealers should receive monetary fines when they are found in non compliance of any rule or portion thereof, instead they should lose their ability to operate as a broker-dealer. You either follow the rules or you don't - it's that simple. 


I would rather pay commission to avoid being routed through a wholesaler like Citadel Securities. 
  
All exchanges should have to quote AND trade in the same increments. 
  
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". 
  
I support the tick size regime proposed by the Commission. 


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. 
  
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. 


Sincerely, 
John Glisson