Subject: Re: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22)
From: Tasha Bertch
Affiliation:

Mar. 07, 2023



To Whom It May Concern, 

I am writing to express my frustration with the current state of the market and the lack of adequate enforcement by the SEC. As a household investor, I have had enough of the constant manipulation, exploitation, and corruption that pervades the financial industry. 

Higher fines that actually serve as a significant deterrent need to be delivered to those firms that make profit through financial crime. Fines should be AT LEAST the amount of money stolen PLUS a significant fine to deter any future criminal activity. Every rule the SEC passes is only as good as the enforcement that backs it, and right now, that enforcement is overwhelmingly lackluster. 

Furthermore, I believe that some broker-dealers should lose their licenses instead of receiving fines that amount to nothing more than a cost of doing business. This is a cost that is often outweighed by the ill-gotten gains obtained through “honest mistakes”. It is unacceptable that these firms can continue to operate in the market after repeatedly circumventing regulations. 

I am unnerved of being routed through wholesalers like Citadel Securities that have been charged over 70 times by the United States government. I would gladly pay 12 cents more a share to avoid being complicit in supporting a firm with such a long record of breaking the law. I would also gladly pay commission to avoid being routed through a wholesaler, especially one with a history of flouting the law. The presence of rebates and other inducements in the marketplace, which are simply payment for order flow by another name, have no place in our markets. These access fees should be reduced to zero; no "take". 

I fully support the harmonization of tick sizes across all exchanges. The fact that some exchanges receive special treatment and are able to leverage that special treatment to build monopolies in some areas of the market is outrageous. All exchanges should have to quote AND trade in the same increments. The markets are supposed to be fair, so make them fair. The SEC needs to take action to prevent monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. 

I support the tick size regime proposed by the Commission, and I urge that the language remain clear and unambiguous. Loose, "reasonable" language makes enforcement difficult or impossible and wastes taxpayer dollars on needless litigation time. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules. 

Finally, I applaud the SEC's efforts to provide individual investors with more information with which to make better investing decisions - especially concerning which firms are allowed to handle our orders. I support the inclusion of odd lot information in the SIP and believe that the exclusion of odd lots from the NBBO is a problem. Odd lots are now a majority of trades in the markets. Within some stocks, they are the vast majority. The exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors - most of the voting public. The SEC should implement a way to fairly and proportionately include odd lots in the calculation of the NBBO. 

I am fed up with the current state of the market, and I demand that the SEC take immediate and decisive action to protect investors and restore integrity to the financial industry. 

Sincerely, 

Tasha Bertch