Mar. 07, 2023
Dear SEC Commissioners, As a household investor, I am writing to express my strong support for the inclusion of odd lots in your proposed rulemaking (S7-30-22) regarding market data infrastructure. The effectiveness of any SEC rule depends entirely on its enforcement. To make a real impact, I believe that imposing more substantial fines that serve as a significant deterrent is necessary. In my opinion, broker-dealers who engage in misconduct should face more severe consequences than just receiving fines that they can easily afford. These fines often do not deter them from continuing to make profits through unethical means, and they end up being just a "cost of doing business." Therefore, revoking their licenses would be a more appropriate punishment. I would not mind paying a slightly higher price per share to avoid being routed through a wholesaler that has been repeatedly charged by the US government. For instance, Citadel Securities, which has a long history of breaking the law, is a wholesaler that I would prefer to avoid, even if it means paying a commission to another broker-dealer. I am in favor of standardizing tick sizes across all exchanges to eliminate the unfair advantage some exchanges have in certain areas of the market. It is unacceptable that some exchanges can use this advantage to establish monopolies, which undermines the positive effects of competition. To ensure fairness in the markets, all exchanges should have the same quoting and trading increments. I am against rebates and other incentives in the marketplace, as they are just a different form of payment for order flow. To eliminate any appearance of impropriety, I believe access fees should be reduced to zero. I support the Commission's proposed tick size regime and any rule structure that is clear and does not rely on ambiguous language. Vague language can lead to loopholes that some firms may exploit, resulting in costly litigation. Therefore, clear and unambiguous language is crucial to effective enforcement. I urge the Commission not to include vague language in its rules. Kind regards, Marcel Boukoura