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

Mar. 06, 2023




Dear Securities and Exchange Commission:

I am writing to you as a household investor, who has become increasingly frustrated with the state of the stock market. I am shocked and appalled by the level of manipulation that Market Makers continue to use - in this case, their attempt to modify the rules to maintain their monopolistic grip on household investors like me, and I hope you take my numerous concerns seriously.

First, I want to address the issue of enforcement. Every rule the SEC passes is only as good as the enforcement that backs it. I am tired of seeing broker-dealers receiving fines that amount to nothing more than a cost of doing business - a cost that is far outweighed by the ill-gotten gains obtained through “honest mistakes”. I want to see higher fines that actually serve as a significant deterrent. Some broker-dealers should lose their licenses instead of receiving fines that are a slap on the wrist.

Second, I would gladly pay $.12 more/share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. It is unacceptable that certain wholesalers with a long record of flouting the law, like Citadel Securities, are still allowed to operate in the market. I would prefer to pay commission to avoid being routed through such wholesalers.

Third, I fully support the harmonization of tick sizes across all exchanges. I was stunned 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. The markets are supposed to be fair, so make them fair. I believe the exclusion of odd lots from the NBBO is also 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 - the majority of the voting public. Please look into a way to fairly, and proportionately, include odd lots in the calculation of the NBBO.

Finally, I am vehemently opposed to 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. 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.

In conclusion, I 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. I believe the inclusion of odd lot information in the SIP is a step in the right direction. I urge you to take action on these issues and create a fair and transparent market that serves the interests of all investors, big and small.





Looking forward! 

Chris Eastvedt