Mar. 06, 2023
Greetings, I have recently become aware that the SEC is accepting comments on this new proposal. I have a couple of thoughts that I'd like to share with you. * Allowing one category of purchasers/sellers of a security with the ability to trade at different "tick sizes" is inherently unfair and creates distrust in the system. The reason is the side that has 3 or more significant digits (0.nnn) trading against a side that has only 2 ($0.nn) would be able to "steal" the trade since they can be slightly higher or lower (depending on the trade) and there is no way for fair competition in trades. * Penalties for violations of any rule should never be solely monetary. There should also always be a "cooling off" period that includes a period of time that the perpetrator is incapable of continuing the violation. This could be as simple as restricting use of the mechanism that allowed the violation - by suspending a trader, suspending the use of the private exchange (dark pool), or suspending access to the public exchange, etc. * Any monetary fine for any violation should be twice as great as the perpetrator was able to unfairly acquire. This provides an incentive for "fair play" since it would no longer be profitable to violate rules which result in financial gain. One-half would go to the SEC for the ability to find more violations, the other half will be returned to the household investors from which the money was unfairly taken. Thank you for your consideration, Edward Ginn