Mar. 07, 2023
Dear Securities and Exchange Commission, I am writing to express my support for the proposed rule changes, which seek to improve the fairness and transparency of the US financial markets. I believe that these changes will be instrumental in protecting individual investors from the predatory practices of some broker-dealers and market makers, such as Citadel Securities. I fully endorse the call for higher fines and more effective enforcement mechanisms. Too often, broker-dealers receive insignificant fines that are simply viewed as the cost of doing business. This sends the wrong message to the industry and allows bad actors to continue their harmful practices. I believe that some broker-dealers should lose their licenses for repeated violations of the rules. Furthermore, I am willing to pay slightly higher fees to ensure that my orders are not routed through firms with a history of regulatory violations. In particular, the fact that Citadel Securities has been charged over 70 times by the US government is deeply concerning. I do not want my investments to be handled by firms with such a track record. I also strongly support the harmonization of tick sizes across all exchanges. It is unacceptable that some exchanges receive preferential treatment, which allows them to build monopolies in certain areas of the market. This undermines the benefits of competition and harms individual investors. I believe that all exchanges should quote and trade in the same increments. I am also opposed to the use of rebates and other inducements in the marketplace. These are simply a form of payment for order flow, which can harm individual investors by incentivizing broker-dealers to route orders to the highest bidder rather than the best execution venue. I would prefer to see access fees reduced to zero. Regarding the proposed tick size regime, I support clear and unambiguous language that does not rely on vague or ambiguous terms. Loose language makes enforcement difficult and wastes taxpayer dollars on needless litigation. Therefore, I urge you to ensure that the tick size rule structure is clear and unambiguous. I also support the inclusion of odd lot information in the SIP. This information can help individual investors make better-informed investment decisions and provide greater transparency into which firms are handling our orders. I am also concerned about the exclusion of odd lots from the NBBO, which can disadvantage individual investors. Therefore, I urge you to look into ways to fairly and proportionately include odd lots in the calculation of the NBBO. In conclusion, I believe that the proposed rule changes are essential for protecting the integrity and fairness of the US financial markets. I urge you to implement them as soon as possible. Thank you for your attention to this matter. Sincerely, Jacob Sánchez Pérez