Subject: EC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22)
From: Andrew O'Donnell
Affiliation:

Mar. 07, 2023

I broadly support this proposal. 



Enforcement is as important as the rules, as a household individual investor I would have more confidence in the market if I actually believed that rules were adequately enforced. Currently I don't believe regulator enforcement is an effective deterrent to rule breaking. 
Dave Lauer puts it very well when he asks "what does it take for one of these entities to lose their licence?" 


Further, I would go on to say that Market Makers, Brokers and Wholsalers do not represent me or my opinions as an individual or household investor (they use the word "retail") I strongly disagree with any claims from these entities to the commission that they represent household investors or that their recommendations are in the best interests of individual investors. They are, and always will be, looking after their own interests. Their profits come ultimately from us, regular folk. That they think they can speak on our behalf would be laughable if it weren't so insulting. 



There is no such thing as free access to the markets. The argument that market makers and wholesalers make; "that retail has it so good" is flawed. Individual investors are paying in other ways, such as not receiving best execution according to the SEC's own data or through information asymmetry giving advantages to large financial entities. 
I do not use a 'free' brokerage any longer for this reason. I gladly, pay commission to avoid being routed through a wholesaler. 


The presence of rebates and other inducements in the marketplace is troubling, this is payment for order flow by another name. 



I support the harmonization of tick sizes across all exchanges. Exchanges should not be granted special advantage over others; all exchanges should have to quote and trade in the same increments as each other. We're all playing by the same rules right? 


Including odd lot information in the SIP is a good idea. The bids and offers of these orders should not be invisible to individual and household investors. 


Odd lots should be included in the NBBO.