Mar. 06, 2023
Dear Sec, I would like to start by saying anything that Citadel proposes for “better markets” is never, and will never be in my best interests and I think I can say the same for the majority of household investors. ENFORCEMENT MATTERS A LOT- without sufficient enforcement rules mean nothing. The public wants higher fines, bigger penalties, and actual consequences. If the fines are a slap on the wrist then offenders look at it as the price of doing business. It’s called crime. And it’s a shady look for the ones who are suppose to be enforcing the rules when the punishment is pennys compared to the money siphoned from crime. The price improvement provided by wholesalers in minimal and not worth the damage they bring to the market. I would gladly pay .64 cents more a share to avoid being routed through a wholesaler (citadel) who’s been charged over 70 times by the US government. It’s incredible they’re still able to operate. If I committed crime at the rate citadel does and other “market makers” for that matter I wouldn’t be able to get a job at Wendy’s. But here they are committing crimes on a daily basis. Draining our markets. Stealing from teachers pensions. I would gladly pay a commission to trade. Nothing in life is free. If I don’t pay fidelity to use their services then I’m not a customer. I’m their product. My data is sold for order flow and ultimately there’s not true market discovery. I’m in full support of harmonizing tick sizes across all exchanges. No exceptions. No vague language. Using words like “reasonable” I want clear cut language and rules. Exact. Not up for debate. Some exchanges shouldn’t be granted an unfair advantage over other exchanges. It leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are suppose to be fair. Please 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". 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. Please SEC help make our markets better. Let’s stop enabling criminals who destroy not only our markets but our world altogether by cellar boxing companies who try to progress for humanity. Thank you! I look forward to seeing change