Mar. 07, 2023
Currently, large firms are able to simply brush off fines and continue their misconduct. In order to effectively enforce market rules we need to ensure the penalties are of an appropriate scale! I strongly believe that heavier fines should be implemented so that market participants are properly encouraged to follow the rules. More serious penalties should apply to repeat offenders, firms should not be able to circumvent the law so easily as to treat fines as a cost of business! As a household investor myself, I would gladly pay extra in order to prevent my order from being routed through a wholesaler with a history of violating the law such as Citadel Securities LLC. I am in full support of harmonizing tick sizes in all exchanges, markets are supposed to be fair and certain exchanges should not be given an advantage over others. All exchanges should quote and trade in the same increments, otherwise, it allows those with access to certain exchanges to subvert normal market pressures for their own benefit. Markets should be an even playing field. I am against rebates and other inducements in the markets, these still essentially function as payment for order flow. Instead, access fees should be reduced to zero, there should be no "take". The tick size system proposed by the Commission will be a suitable solution for keeping markets fair. It is important that these changes are clear and without the use of vague language. Using language such as "has a reasonable amount of liquidity at the NBBO" is vague and will be used by firms to allow them to continue circumventing the rules. A clear and unambiguous tick size rule structure is paramount for keeping things fair, vagueness has no place in regulation! I am in support of odd lot information being included in the SIP, and I am pleased with the Commission's efforts to provide greater transparency to individual investors. This information will allow us to make more informed decisions - especially concerning which firms are able to handle our orders. A large proportion of trades within markets are odd lots, I see no reason for so many bids and offers to be kept invisible. The inclusion of odd lot information is critical for keeping markets fair. I believe the exclusion of odd lots from the NBBO is a highly concerning problem, with such a high proportion of trades being odd lots, it would be very concerning for the odd lot information required wasn't included in this rule, excluding odd lot information is excluding individual investors! Thank you for your consideration