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

Mar. 07, 2023

To Whom It May Concern, 


Thank you for proposing change and helping the American people not continue to be at the bottom of a very steep hill.  I understand change can be scary at times but if we don’t evolve then we get left behind and right now the American people of the working middle class and lower are getting left behind and worst.  With the changes being proposed I believe we can help start to make the changes necessary to preserve Americans money and really give back to the working middle class and below.   


With each new rule that gets passed I am also worried that these huge corporation Market Makers etc. may not be policed as hard as they should to make sure regulations are being upheld.  It’s of my opinion that the fines for not following/breaking regulations needs to increase steeply to deter from the law being broken.  I would propose that the fine  at the very least doubles with every single infraction (1, 2, 4, 8, 16, 36, 72, etc.) and this may help deter the constant abuse.   


I also, to be clear, don’t believe fines are the only way of punishment because to some companies it’s the cost of doing business.  Every “mistake” they make costs the average Joe dearly.  The SEC should take the power they are able to enforce and companies should lose their licenses instead. 


If I could guarantee my transactions were not being touted through wholesaler, I would gladly pay $0.12 more a share. I also would prefer to pay a commission to not be routed through a wholesaler as there is no need for a middleman in this age of technology.  


I think the harmonization across every exchange lot tick sizes is a must and gets my full support.  We need to level the playing field and not give special exceptions.  These advantages may at first be birthed in good light but eventually turn rotten due to greed and manipulation to get ahead.  Competition is best for everyone to be fair and in order to compete to each exchange needs an even change 



Regarding PFOF or any other rebate/inducements in the marketplace, I do not support these type of actions.  The SEC should reduce fees to see and have no take. 


I truely believe we need more direct and clear wording that even the average Joe can use.  If it cannot be explained to a child then there is room for lawyers to be involved and evade the very thing the rules are trying to enforce.  The tick size proposed has my full support and as previously mentions please remove all vague language and make the requirements very clear and simple so there is no ambiguity. 


The SIP should very much include odd lots and I am grateful as household investors (retail) would have more information to make clearer investment decisions.   


Odd lots make up the majority of trades in the market and if we exclude odd lots from the NBBO it would be problematic.  With some stocks, ofd lots would make up the largest portion being traded.  As a household investor (retail) I ask you find a fair way to include off lots in the calculation of the NBBO. 


Thank you for your time and please keep up the good fight and hard work. 


-Shayne Gallagher