Mar. 06, 2023
Dear SEC, The efficacy of the SEC's rules depends entirely on the strength of their enforcement, and I strongly believe that imposing more substantial fines is necessary to create a truly effective deterrent against violations. Merely imposing fines that are insignificant in comparison to the profits obtained through fraudulent activities only serves to incentivize bad behavior, which is why I believe that revoking the licenses of certain broker-dealers is a necessary step towards enforcing accountability in the financial industry. I would be willing to pay a slightly higher price per share to ensure that my trades are not routed through a wholesaler that has a history of being charged by the United States government over 70 times, as the potential risks to my investments far outweigh the marginal increase in cost. (https://files.brokercheck.finra.org/firm/firm_116797.pdf). Given the track record of Citadel Securities and their history of disregarding regulations, I would be more than willing to pay commission to ensure that my trades are not routed through their platform, as the potential consequences of doing so could be severe. I strongly endorse the idea of standardizing tick sizes across all exchanges, as it is unfair for some exchanges to receive preferential treatment and utilize it to establish monopolies in certain market segments. To promote healthy competition, all exchanges should have to quote and trade in the same increments, without any exceptions. It is imperative that we level the playing field and prevent any exchange from having an unfair advantage, as this will ultimately undermine the integrity of the markets and defeat the purpose of competition. I have a strong aversion to rebates and other incentives in the marketplace, as they essentially amount to payment for order flow in a different form. Instead, I believe it would be better to eliminate access fees altogether, so there is no "take" whatsoever. This would help to eliminate any conflicts of interest and ensure that brokers are acting in the best interest of their clients, rather than being swayed by financial incentives. Ultimately, the markets should be transparent, fair, and free from any undue influence, and eliminating access fees is a step in the right direction. I fully endorse the tick size regime put forth by the Commission, and I also believe that any structure for the rules must be unambiguous and devoid of vague language. I have seen instances where certain funds and firms have requested language such as "has a reasonable amount of liquidity at the NBBO," which essentially allows them to ignore the rules if they believe they can get away with it. The use of vague language in the rules only serves to create confusion and makes enforcement more difficult, resulting in wasted taxpayer dollars on litigation. Therefore, I strongly advocate for clear and unambiguous language in the tick size rules, and I implore the Commission to avoid incorporating any vague language in the application of the rules. I am a strong proponent of including odd lot information in the SIP, and I commend the Commission for their efforts to provide individual investors with greater transparency and more information to aid in their investing decisions - particularly in regards to which firms are authorized to handle their orders. It is worth noting that, according to recent data (55%; from https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/) , the majority of trades in the markets are odd lots (55%), with some tickers experiencing even higher rates. Given the prevalence of odd lots in the markets, it is essential that their bids and offers be visible to all investors, as this promotes transparency and creates a level playing field. If the Commission were to remove odd lot information from this rule, it would severely damage my faith in the U.S. markets and likely result in reduced investor confidence overall. Therefore, I fully support the inclusion of odd lot information in the SIP and urge the Commission to maintain this requirement moving forward. I strongly believe that the exclusion of odd lots from the NBBO calculation is a major problem. Given that odd lots now represent the majority of trades in the markets and can often make up a significant portion of trading volume for certain stocks, the exclusion of odd lots from the price of a stock effectively shuts out a large portion of individual investors - essentially, most of the voting public. This is a major concern, as it prevents many investors from being able to obtain a fair and accurate representation of a stock's price. As such, I urge the Commission to investigate potential solutions for fairly and proportionately including odd lots in the calculation of the NBBO. It is important that we find a way to ensure that all investors, regardless of the size of their trades, have equal access to accurate pricing information in order to make informed investment decisions. Yours Sincerely, Colin Clarry Tinun Household Investor