Subject: Re: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22) TALKING POINTS TO STITCH TOGETHER: Every rule the SEC passes is only as good as the enforcement that backs it. I want t...
From: Adam Rensel
Affiliation:

Mar. 07, 2023

Hi there! Rules are great and all, but any rule the sec adopts only matters if the enforcement action behind it has enough teeth to be a deterrent to breaking them. Fines should
 be in amounts greater than money obtained while breaking the rules. Brokers should also lose their licenses given enough infractions. Consequences for breaking rules should not be able to be passed off as the cost of the doing business. I would gladly go back
 to paying for trades if it means bad actors are being held responsible for breaking laws and rules. 
I also would be glad to pay extra to have more control over where my orders go and how they are handled. We deserve to know where our money is going and where shares are coming from. Payment for order flow and internalization hurt all investors whose intentions don’t align to whatever hedge fund or market maker processing their orders. I support the normalization of tick sizes across all exchanges, it seems crazy to me that odd lots aren’t taken into account for the nbbo or other public data feeds. All trades matter and should be part of the data stream. With modern electronic systems this should be straightforward. The current system gives a large advantage to investors trading in whole lots, that most household investors don’t have the capital to trade in. I’ve noticed comments from large funds that really want verbiage to include “reasonable” or concerns about liquidity. This verbiage should be avoid3d at all costs, as it only serves to open loopholes that funds with infinite money for litigation can exploit. This is finance, there are set concrete numbers for everything involved. Markets will adapt and as a result become more fair if these loopholes are never allowed to come into existence and are removed for current rules. Thank you! 
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- Adam Rensel, Web Developer