Mar. 07, 2023
I'd first like to thank the SEC on this proposal No. 57-30-22. Although it should be said that any and all regulation or rules passed are only as good as the enforcement that would back it. To actually disincentivize violations, fines and punishments need to be substantial enough. I believe broker-dealers should lose their licenses instead of receiving fines that are small in comparison to the ill-gotten gains obtained through conscious violations of rules and regulations such as these in the stated proposal. As a principle, I'd rather pay commission to avoid being routed through a wholesaler that has been charged more than 70 times by the US Government. (https://files.brokercheck.finra.org/firm/firm_116797.pdf). Reading the cited document of the violations and the sanctions is a surreal experience. The frequency of rule trespassing committed by Citadel Securities is enough to deem it a systematic occurrence. Thus, I'd rather not support such a business. Furthermore, I see no reason for tick sizes that differ across exchanges. That wholesalers have the ability to trade in sub-penny increments while everyone else does not, indicates that the playing field is unequal when these participants compete for order flow. Make the markets fair! Last but not least, I find it hard to understand why odd lot orders do not affect the price. Therefore, I see inclusion of odd lot information in the Securities Information Processor, as a must for a more transparent and free market. Odd lot orders should impact the NBBO and have a concrete effect on price and brokers' duty of best execution. Anything else is financial market discrimination. Sincerely, Felix Skoog, Sweden